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 criminal revision petition challenging cheque dishonour proceedings under Section 138 of Negotiable Instruments Act. Court held that at process issuance stage, presumption under Section 139 operates in complainant's favor. Disputed factual questions regarding prior civil settlement cannot be adjudicated during preliminary proceedings. Mere absence of supporting evidence by complainant does not automatically invalidate criminal complaint. Petitioner's contentions regarding complete resolution of disputes were deemed premature, requiring full trial examination. Petition rejected, criminal proceedings allowed to continue.
HC dismissed criminal revision petition challenging cheque dishonour proceedings under Section 138 of Negotiable Instruments Act. Court held that at process issuance stage, presumption under Section 139 operates in complainant's favor. Disputed factual questions regarding prior civil settlement cannot be adjudicated during preliminary proceedings. Mere absence of supporting evidence by complainant does not automatically invalidate criminal complaint. Petitioner's contentions regarding complete resolution of disputes were deemed premature, requiring full trial examination. Petition rejected, criminal proceedings allowed to continue.
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