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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Successive bail was denied because no substantial change in circumstances was demonstrated; the investigation is complete and both charge sheet and supplementary charge sheet have been filed, with material prima facie implicating the applicant for impersonation and conspiracy to extract illegal gratification. Electronic evidence-CCTV placing the applicant at the negotiation site, voice samples, and recorded telephone conversations-supports the prosecution case, and witness identification further corroborates involvement. The applicant's alleged evasion of process, reluctance to provide voice samples, and non-cooperation during investigation were held as factors weighing against bail, leading to rejection of the second bail application.
Successive bail was denied because no substantial change in circumstances was demonstrated; the investigation is complete and both charge sheet and supplementary charge sheet have been filed, with material prima facie implicating the applicant for impersonation and conspiracy to extract illegal gratification. Electronic evidence-CCTV placing the applicant at the negotiation site, voice samples, and recorded telephone conversations-supports the prosecution case, and witness identification further corroborates involvement. The applicant's alleged evasion of process, reluctance to provide voice samples, and non-cooperation during investigation were held as factors weighing against bail, leading to rejection of the second bail application.
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