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 allowed the Applicant's regular bail application under Article 21, directing immediate release subject to stringent bail conditions and personal bonds. The Court found prolonged pretrial detention (custody since 05.09.2024, over 15 months), absence of framed charges and imminent trial, parity with a co-accused already granted bail, and lack of a clear prima facie case for money-laundering collectively satisfied the triple-test for bail. Risk of tampering was mitigated by recorded statements of material witnesses and advanced material collection. The Court held continued incarceration would be punitive; breach of bail conditions will invite prompt cancellation and permits the Enforcement Directorate to take appropriate action.
The HC allowed the Applicant's regular bail application under Article 21, directing immediate release subject to stringent bail conditions and personal bonds. The Court found prolonged pretrial detention (custody since 05.09.2024, over 15 months), absence of framed charges and imminent trial, parity with a co-accused already granted bail, and lack of a clear prima facie case for money-laundering collectively satisfied the triple-test for bail. Risk of tampering was mitigated by recorded statements of material witnesses and advanced material collection. The Court held continued incarceration would be punitive; breach of bail conditions will invite prompt cancellation and permits the Enforcement Directorate to take appropriate action.
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