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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Compounding of a cheque-dishonour offence under Section 138 of the Negotiable Instruments Act was permitted even after conviction because the petitioner had entered into a post-conviction settlement and paid the entire compensation, with the complainant raising no objection. The HC applied the principle that Section 147 permits compounding after conviction and accepted the compromise in light of the settlement and payment already made. The conviction and sentence were accordingly recalled, the offence was compounded, and the petitioner was acquitted.
Compounding of a cheque-dishonour offence under Section 138 of the Negotiable Instruments Act was permitted even after conviction because the petitioner had entered into a post-conviction settlement and paid the entire compensation, with the complainant raising no objection. The HC applied the principle that Section 147 permits compounding after conviction and accepted the compromise in light of the settlement and payment already made. The conviction and sentence were accordingly recalled, the offence was compounded, and the petitioner was acquitted.
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