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 dismissed the appeal, upholding the acquittal of the respondent in a gold smuggling case. The court found critical evidentiary gaps in the prosecution's case, including lack of credible witness testimony directly implicating the respondent and absence of proper forensic certification of the recovered item. The key witness contradicted the prosecution's narrative, creating reasonable doubt about the respondent's involvement. The court emphasized the importance of rigorous investigation and conclusive evidence, ultimately extending benefit of doubt to the respondent and affirming the lower court's acquittal under Section 135(1)(a) of the Customs Act, 1962.
HC dismissed the appeal, upholding the acquittal of the respondent in a gold smuggling case. The court found critical evidentiary gaps in the prosecution's case, including lack of credible witness testimony directly implicating the respondent and absence of proper forensic certification of the recovered item. The key witness contradicted the prosecution's narrative, creating reasonable doubt about the respondent's involvement. The court emphasized the importance of rigorous investigation and conclusive evidence, ultimately extending benefit of doubt to the respondent and affirming the lower court's acquittal under Section 135(1)(a) of the Customs Act, 1962.
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