Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Directors cannot singly obtain quashment of criminal proceedings originating from the company for offences under the Negotiable Instruments Act where the company is the primary offender; vicarious liability attaches to persons who at the time of the offence were in charge of and responsible for the conduct of the company's business, and absence of company impleadment renders director-only petitions for quashment not maintainable. The legal effect is that challenges to issuance of process in company-originated cheque dishonour complaints cannot be sustained solely by directors without the company, and trial proceedings should proceed expeditiously.
Directors cannot singly obtain quashment of criminal proceedings originating from the company for offences under the Negotiable Instruments Act where the company is the primary offender; vicarious liability attaches to persons who at the time of the offence were in charge of and responsible for the conduct of the company's business, and absence of company impleadment renders director-only petitions for quashment not maintainable. The legal effect is that challenges to issuance of process in company-originated cheque dishonour complaints cannot be sustained solely by directors without the company, and trial proceedings should proceed expeditiously.
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