Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
SC held that stamp vendors are public servants under the Prevention of Corruption Act. The Court adopted a purposive interpretation of "public servant" definition, emphasizing the nature of public duty performed. The appellant's status as a government-remunerated stamp vendor facilitating revenue collection qualifies him as a public servant. However, the prosecution failed to establish beyond reasonable doubt the demand and acceptance of illegal gratification. Consequently, the Court set aside the conviction under Sections 7 and 13(1)(d) read with Section 13(2) of the PC Act, finding insufficient evidence to prove bribery. The appeal was allowed, quashing the trial court and high court's previous convictions.
SC held that stamp vendors are public servants under the Prevention of Corruption Act. The Court adopted a purposive interpretation of "public servant" definition, emphasizing the nature of public duty performed. The appellant's status as a government-remunerated stamp vendor facilitating revenue collection qualifies him as a public servant. However, the prosecution failed to establish beyond reasonable doubt the demand and acceptance of illegal gratification. Consequently, the Court set aside the conviction under Sections 7 and 13(1)(d) read with Section 13(2) of the PC Act, finding insufficient evidence to prove bribery. The appeal was allowed, quashing the trial court and high court's previous convictions.
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