Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Section 37A seizure of equivalent domestic assets was upheld where foreign proceedings and control of overseas entities gave reason to believe that foreign exchange derived from those entities remained held abroad in contravention of FEMA. Confirmation of seizure operates as an interim protective measure pending adjudication, particularly where no repatriation or disclosure of the foreign exchange is shown. Applying Section 37A to foreign exchange acquired after its commencement and continuing to be held abroad does not constitute retrospective application. Foreign employment permits alone do not establish non-resident status without evidence of year-wise Indian stay or an intention to remain abroad indefinitely; an administratrix's personal residential status does not determine the Estate's alleged foreign holding.
Section 37A seizure of equivalent domestic assets was upheld where foreign proceedings and control of overseas entities gave reason to believe that foreign exchange derived from those entities remained held abroad in contravention of FEMA. Confirmation of seizure operates as an interim protective measure pending adjudication, particularly where no repatriation or disclosure of the foreign exchange is shown. Applying Section 37A to foreign exchange acquired after its commencement and continuing to be held abroad does not constitute retrospective application. Foreign employment permits alone do not establish non-resident status without evidence of year-wise Indian stay or an intention to remain abroad indefinitely; an administratrix's personal residential status does not determine the Estate's alleged foreign holding.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
