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 revision and sustained conviction under s.138 of the NI Act. The accused admitted borrowing Rs.1,50,000 and issuing a security/blank cheque for Rs.50,000; issuance and signature were undisputed, thereby attracting the statutory presumptions u/s 118(a) and 139. The accused failed to rebut the presumption: his s.313 CrPC statement and uncorroborated denial that payment was made were held insufficient, and no defence evidence was led. Notice was deemed served. Trial court's compensation of Rs.68,000 was affirmed as reasonable given the delay and loss of use; no interference warranted with concurrent findings and sentence.
HC dismissed the revision and sustained conviction under s.138 of the NI Act. The accused admitted borrowing Rs.1,50,000 and issuing a security/blank cheque for Rs.50,000; issuance and signature were undisputed, thereby attracting the statutory presumptions u/s 118(a) and 139. The accused failed to rebut the presumption: his s.313 CrPC statement and uncorroborated denial that payment was made were held insufficient, and no defence evidence was led. Notice was deemed served. Trial court's compensation of Rs.68,000 was affirmed as reasonable given the delay and loss of use; no interference warranted with concurrent findings and sentence.
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