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 held that the legal notice served on two partners of the partnership firm was valid, despite not being directly addressed to the firm. The blank security cheque issued in 2009 was deemed a legitimate instrument for discharging outstanding debt. The court rejected technical objections regarding notice service and partner liability, finding prima facie evidence of legally enforceable liability. The third petitioner (partner's wife) cannot be discharged at the summoning stage without proving her non-involvement. The complaint under Section 138 of NI Act stands, and the petition challenging the criminal proceedings was dismissed.
HC held that the legal notice served on two partners of the partnership firm was valid, despite not being directly addressed to the firm. The blank security cheque issued in 2009 was deemed a legitimate instrument for discharging outstanding debt. The court rejected technical objections regarding notice service and partner liability, finding prima facie evidence of legally enforceable liability. The third petitioner (partner's wife) cannot be discharged at the summoning stage without proving her non-involvement. The complaint under Section 138 of NI Act stands, and the petition challenging the criminal proceedings was dismissed.
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