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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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.
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