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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The HC admitted the criminal appeal in a dishonour-of-cheque matter but conditioned relief on pre-deposit of the compensation award under Section 148 of the NI Act, finding no exceptional circumstances to dispense with that requirement. The court recorded that the petitioners were heard and a reasoned order was rendered; the cheques were dishonoured in 2009 and conviction followed in 2024. The petitioners' invocation of Section 91 CrPC was rejected. Although the court acknowledged precedential authority permitting discretion to waive pre-deposit where specific reasons are recorded, it found no cogent or special reasons advanced by the petitioners and consequently dismissed the application.
The HC admitted the criminal appeal in a dishonour-of-cheque matter but conditioned relief on pre-deposit of the compensation award under Section 148 of the NI Act, finding no exceptional circumstances to dispense with that requirement. The court recorded that the petitioners were heard and a reasoned order was rendered; the cheques were dishonoured in 2009 and conviction followed in 2024. The petitioners' invocation of Section 91 CrPC was rejected. Although the court acknowledged precedential authority permitting discretion to waive pre-deposit where specific reasons are recorded, it found no cogent or special reasons advanced by the petitioners and consequently dismissed the application.
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