Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Section 6(3) of FEMA continued to govern foreign-remittance contraventions committed while it was in force despite its subsequent omission. Delayed reporting of foreign investment and delayed share allotment constitute civil regulatory breaches for which liability does not require mens rea unless the statute so provides; later compliance and claimed bona fides do not make the defaults technical. Confiscation under FEMA is discretionary and additional to monetary penalty, requiring a fact-based judicial assessment, including misuse of remittances in a restricted real-estate sector. Director liability depends on responsibility for company affairs: liability does not attach without proof of control, but may attach where managerial responsibility, knowledge, or lack of due diligence is established.
Section 6(3) of FEMA continued to govern foreign-remittance contraventions committed while it was in force despite its subsequent omission. Delayed reporting of foreign investment and delayed share allotment constitute civil regulatory breaches for which liability does not require mens rea unless the statute so provides; later compliance and claimed bona fides do not make the defaults technical. Confiscation under FEMA is discretionary and additional to monetary penalty, requiring a fact-based judicial assessment, including misuse of remittances in a restricted real-estate sector. Director liability depends on responsibility for company affairs: liability does not attach without proof of control, but may attach where managerial responsibility, knowledge, or lack of due diligence is established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
