Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The article addresses discharge jurisdiction in criminal proceedings and holds that at the discharge stage the court must assess only whether a prima facie case or strong suspicion exists to warrant trial, not conduct a mini-trial; applying this test, the Special Court correctly refused discharge of the petitioner where admissible statements under the Customs Act, approver confessions, and other particularised particulars in the final report furnished sufficient material to proceed. The piece further explains that voluntariness, corroboration, and the probative weight of approver statements, extra judicial confessions and CCTV visuals are factual matters for trial and do not mandate discharge on the present record.
The article addresses discharge jurisdiction in criminal proceedings and holds that at the discharge stage the court must assess only whether a prima facie case or strong suspicion exists to warrant trial, not conduct a mini-trial; applying this test, the Special Court correctly refused discharge of the petitioner where admissible statements under the Customs Act, approver confessions, and other particularised particulars in the final report furnished sufficient material to proceed. The piece further explains that voluntariness, corroboration, and the probative weight of approver statements, extra judicial confessions and CCTV visuals are factual matters for trial and do not mandate discharge on the present record.
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