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...
High Court reviewed a magistrate's refusal to allow a director to travel abroad where corporate entities had been penalised for alleged bogus input tax credits. The Court held that corporate penalties and revenue loss alone do not justify depriving an individual of personal liberty or the right to travel abroad; absent material showing personal flight risk or intent to evade process, travel may be permitted. The Court applied principles protecting personal liberty, weighed offence gravity and case stage, and allowed travel subject to conditions including a security deposit, itinerary and passport disclosure and cooperation with investigators.
High Court reviewed a magistrate's refusal to allow a director to travel abroad where corporate entities had been penalised for alleged bogus input tax credits. The Court held that corporate penalties and revenue loss alone do not justify depriving an individual of personal liberty or the right to travel abroad; absent material showing personal flight risk or intent to evade process, travel may be permitted. The Court applied principles protecting personal liberty, weighed offence gravity and case stage, and allowed travel subject to conditions including a security deposit, itinerary and passport disclosure and cooperation with investigators.
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