Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Contempt for breach of an undertaking requires a clear, express and unambiguous commitment that demonstrates a firm obligation to act or refrain from acting. A statement merely clarifying that a proposed acquisition would not proceed does not, without more, constitute an undertaking enforceable through contempt. Foreign money decrees of superior courts in reciprocating territories may be prima facie executable in India, with comity of nations relevant at the interlocutory stage. Where corporate transactions and changes of control indicate possible asset dissipation, interim protection and adequate security may be maintained pending execution. Questions concerning veil lifting and the liability of family-controlled entities remain for determination in execution proceedings.
Contempt for breach of an undertaking requires a clear, express and unambiguous commitment that demonstrates a firm obligation to act or refrain from acting. A statement merely clarifying that a proposed acquisition would not proceed does not, without more, constitute an undertaking enforceable through contempt. Foreign money decrees of superior courts in reciprocating territories may be prima facie executable in India, with comity of nations relevant at the interlocutory stage. Where corporate transactions and changes of control indicate possible asset dissipation, interim protection and adequate security may be maintained pending execution. Questions concerning veil lifting and the liability of family-controlled entities remain for determination in execution proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
