Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Insolvency moratorium does not shield company officers from cheque dishonour prosecution for liability arising before corporate insolvency proceedings...
Arm's-length remuneration of an Indian associated enterprise treated as a dependent agent permanent establishment is discussed as precluding further profit attribution to the non-resident where no transfer-pricing adjustment is made. The notes describe this approach as applying on identical facts to challenges concerning business connection, permanent establishment and attribution of profits. They also address interest on an income-tax refund, stating that it is not effectively connected with the alleged Indian permanent establishment and should be taxed under the interest article of the India-Singapore treaty rather than under normal domestic provisions.
Arm's-length remuneration of an Indian associated enterprise treated as a dependent agent permanent establishment is discussed as precluding further profit attribution to the non-resident where no transfer-pricing adjustment is made. The notes describe this approach as applying on identical facts to challenges concerning business connection, permanent establishment and attribution of profits. They also address interest on an income-tax refund, stating that it is not effectively connected with the alleged Indian permanent establishment and should be taxed under the interest article of the India-Singapore treaty rather than under normal domestic provisions.
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