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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SC held that summons issued by a police officer directing a lawyer to produce client-related documents is impermissible; such production must occur before a court which will peruse the material, hear the witness, and adjudicate objections under Section 132 of the BSA. The court must ensure presence of the lawyer, the client and any technically qualified person the lawyer or client requests for examination of digital devices. The practice of law encompasses non-litigious work; fly-in foreign visits are fact-sensitive and regulable. In-house counsel's employment nexus may limit privilege. Investigating agencies are cautioned against impinging privilege and fundamental rights. The suo motu proceedings were disposed and the summons set aside.
SC held that summons issued by a police officer directing a lawyer to produce client-related documents is impermissible; such production must occur before a court which will peruse the material, hear the witness, and adjudicate objections under Section 132 of the BSA. The court must ensure presence of the lawyer, the client and any technically qualified person the lawyer or client requests for examination of digital devices. The practice of law encompasses non-litigious work; fly-in foreign visits are fact-sensitive and regulable. In-house counsel's employment nexus may limit privilege. Investigating agencies are cautioned against impinging privilege and fundamental rights. The suo motu proceedings were disposed and the summons set aside.
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