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 dismissed the petition and upheld the trial court's orders permitting production of departmental documents under s.91 Cr.P.C., holding the provision may be invoked at any stage if necessary or desirable for investigation, inquiry or trial. The court found the additional notices were relevant official records bearing on alleged failure to file returns under s.276CC, and their production did not amend the complaint or vitiate the substratum of the prosecution. The petitioner retains full opportunity to cross-examine and contest evidentiary value. Exercise of s.482 Cr.P.C. relief was declined as neither illegality nor miscarriage of justice was made out; impugned orders are sustained.
The HC dismissed the petition and upheld the trial court's orders permitting production of departmental documents under s.91 Cr.P.C., holding the provision may be invoked at any stage if necessary or desirable for investigation, inquiry or trial. The court found the additional notices were relevant official records bearing on alleged failure to file returns under s.276CC, and their production did not amend the complaint or vitiate the substratum of the prosecution. The petitioner retains full opportunity to cross-examine and contest evidentiary value. Exercise of s.482 Cr.P.C. relief was declined as neither illegality nor miscarriage of justice was made out; impugned orders are sustained.
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