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...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
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.
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