Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC granted bail in a currency and gold smuggling case under Customs Act 1962, FEMA 1999, and FEMR 2000. While DRI intercepted accused at airport and recorded conversations with co-accused, prosecution lacked strong evidence linking conversations to specific transactions. Court emphasized that confessional statements u/s 108 of Customs Act, though admissible, require independent corroboration for conviction. Considering accused's clean criminal record, jail time since arrest, and undertaking to cooperate with trial, HC allowed bail application. Court noted need to examine whether seized gold falls under prohibited or restricted category during trial. Bail granted with conditions preventing evidence tampering and witness intimidation.
HC granted bail in a currency and gold smuggling case under Customs Act 1962, FEMA 1999, and FEMR 2000. While DRI intercepted accused at airport and recorded conversations with co-accused, prosecution lacked strong evidence linking conversations to specific transactions. Court emphasized that confessional statements u/s 108 of Customs Act, though admissible, require independent corroboration for conviction. Considering accused's clean criminal record, jail time since arrest, and undertaking to cooperate with trial, HC allowed bail application. Court noted need to examine whether seized gold falls under prohibited or restricted category during trial. Bail granted with conditions preventing evidence tampering and witness intimidation.
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