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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In a second application for regular bail in an SFIO prosecution alleging diversion of cooperative society funds and offences including fraud under the Companies Act, the court considered whether prolonged incarceration and delay in trial justified relaxation of the twin conditions under s.212(6). While acknowledging that such conditions may be diluted where incarceration is unduly prolonged, it held that a successive bail plea must still demonstrate a substantial change in circumstances. Given the gravity of allegations (including large-scale siphoning), absence of substantiation of claimed repayment, and the prior reasoned rejection of bail affirmed by the apex court, no such change was shown; bail was refused and the trial court was directed to expedite the trial. - HC
In a second application for regular bail in an SFIO prosecution alleging diversion of cooperative society funds and offences including fraud under the Companies Act, the court considered whether prolonged incarceration and delay in trial justified relaxation of the twin conditions under s.212(6). While acknowledging that such conditions may be diluted where incarceration is unduly prolonged, it held that a successive bail plea must still demonstrate a substantial change in circumstances. Given the gravity of allegations (including large-scale siphoning), absence of substantiation of claimed repayment, and the prior reasoned rejection of bail affirmed by the apex court, no such change was shown; bail was refused and the trial court was directed to expedite the trial. - HC
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