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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Prima facie material in the FIR and case diary showed involvement in offences under the Prevention of Corruption Act, and the Court held that custodial interrogation was necessary to confront the applicant with incriminating evidence. The allegations were treated as part of a serious economic offence involving a deep-rooted conspiracy and public funds, which weighed against discretionary anticipatory bail. The plea of parity failed because the earlier coordinate Bench order arose in a different factual setting, and parity with co-accused who had obtained regular bail after substantial custody was not comparable to an anticipatory bail claim. Anticipatory bail was therefore rejected.
Prima facie material in the FIR and case diary showed involvement in offences under the Prevention of Corruption Act, and the Court held that custodial interrogation was necessary to confront the applicant with incriminating evidence. The allegations were treated as part of a serious economic offence involving a deep-rooted conspiracy and public funds, which weighed against discretionary anticipatory bail. The plea of parity failed because the earlier coordinate Bench order arose in a different factual setting, and parity with co-accused who had obtained regular bail after substantial custody was not comparable to an anticipatory bail claim. Anticipatory bail was therefore rejected.
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