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 dominant issue was whether non-communication of grounds of arrest in writing vitiated the arrest and warranted grant of bail under Article 22(1). The Court held that "grounds of arrest" are the factual basis forming the arresting officer's opinion that an offence was committed, distinct from "reasons" addressing necessity to arrest. It further held that Article 22(1) does not require the grounds to be written on a separate sheet; furnishing any document containing the grounds amounts to written communication. Since the arrest memo supplied at the time of arrest contained and communicated the grounds in writing, there was no violation of Article 22(1), and bail was refused. - HC
The dominant issue was whether non-communication of grounds of arrest in writing vitiated the arrest and warranted grant of bail under Article 22(1). The Court held that "grounds of arrest" are the factual basis forming the arresting officer's opinion that an offence was committed, distinct from "reasons" addressing necessity to arrest. It further held that Article 22(1) does not require the grounds to be written on a separate sheet; furnishing any document containing the grounds amounts to written communication. Since the arrest memo supplied at the time of arrest contained and communicated the grounds in writing, there was no violation of Article 22(1), and bail was refused. - HC
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