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 court addressed whether bail should be granted where prosecution relied on stereotyped witness statements, co-accused confessions, supplementary charge-sheet material obtained without prior leave, and documentary/digital evidence. It found the rice-miller statements prima facie verbatim and mechanically recorded-weakening their probative value-while reiterating that co-accused statements can only corroborate and not solely implicate; the supplementary material collected post charge-sheet cannot prejudice liberty. No contemporaneous documents link the applicant to policy decisions, and there is no specific material showing risk of flight, tampering or influencing witnesses. Balancing these factors and custody already undergone, bail was granted subject to conditions. - HC
The court addressed whether bail should be granted where prosecution relied on stereotyped witness statements, co-accused confessions, supplementary charge-sheet material obtained without prior leave, and documentary/digital evidence. It found the rice-miller statements prima facie verbatim and mechanically recorded-weakening their probative value-while reiterating that co-accused statements can only corroborate and not solely implicate; the supplementary material collected post charge-sheet cannot prejudice liberty. No contemporaneous documents link the applicant to policy decisions, and there is no specific material showing risk of flight, tampering or influencing witnesses. Balancing these factors and custody already undergone, bail was granted subject to conditions. - HC
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