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 exercised inherent powers to allow compounding of offense under Section 138 of Negotiable Instruments Act based on compromise between parties, despite conviction being upheld at appellate stage. While acknowledging that inherent powers must be used sparingly, HC determined intervention was justified to prevent miscarriage of justice and honor parties' settlement. Court addressed the challenge of late-stage compounding requests and lack of explicit guidance in Section 147 NI Act regarding timing and procedure for compounding. Criminal revision case disposed of per compromise terms, effectively nullifying earlier conviction and sentence. Decision emphasized courts' discretionary power to permit compounding when serving interests of justice, even post-conviction.
HC exercised inherent powers to allow compounding of offense under Section 138 of Negotiable Instruments Act based on compromise between parties, despite conviction being upheld at appellate stage. While acknowledging that inherent powers must be used sparingly, HC determined intervention was justified to prevent miscarriage of justice and honor parties' settlement. Court addressed the challenge of late-stage compounding requests and lack of explicit guidance in Section 147 NI Act regarding timing and procedure for compounding. Criminal revision case disposed of per compromise terms, effectively nullifying earlier conviction and sentence. Decision emphasized courts' discretionary power to permit compounding when serving interests of justice, even post-conviction.
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