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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The HC granted regular bail to an 86-year-old petitioner in a PMLA case, finding him "infirm" under the proviso to Section 45(1). While not deemed "sick" as per the AIIMS medical board's opinion that his ailments could be treated in jail, the Court determined his cognitive impairment, pseudodementia, recurrent dizziness, history of falls, and need for constant monitoring qualified him as "infirm." This exempted him from meeting the twin test requirements of Section 45(1). The Court also noted he satisfied the triple test for bail (no flight risk, witness influence, or evidence tampering) and considered the inevitable trial delay given the case's complexity (17 accused, 66 companies, 121 witnesses, and over 77,000 pages of documents). Bail was granted subject to conditions.
The HC granted regular bail to an 86-year-old petitioner in a PMLA case, finding him "infirm" under the proviso to Section 45(1). While not deemed "sick" as per the AIIMS medical board's opinion that his ailments could be treated in jail, the Court determined his cognitive impairment, pseudodementia, recurrent dizziness, history of falls, and need for constant monitoring qualified him as "infirm." This exempted him from meeting the twin test requirements of Section 45(1). The Court also noted he satisfied the triple test for bail (no flight risk, witness influence, or evidence tampering) and considered the inevitable trial delay given the case's complexity (17 accused, 66 companies, 121 witnesses, and over 77,000 pages of documents). Bail was granted subject to conditions.
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