Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
The HC accepted the Petitioner's undertaking that the cumulative funds in the attached bank accounts (approximately Rs. 10,00,000) will not be withdrawn or otherwise dealt with and treated counsel's statement as a binding undertaking to the Court; the undertaking must be strictly complied with. The Court observed that continued attachment would cause disproportionate prejudice by preventing receipt and use of remittances for operational needs (e.g., employee payments) without benefit to the Respondent. Having recorded and accepted the undertaking, the HC disposed of the petition on that basis, subject to enforcement of the undertaking and any future application for variation or recall.
The HC accepted the Petitioner's undertaking that the cumulative funds in the attached bank accounts (approximately Rs. 10,00,000) will not be withdrawn or otherwise dealt with and treated counsel's statement as a binding undertaking to the Court; the undertaking must be strictly complied with. The Court observed that continued attachment would cause disproportionate prejudice by preventing receipt and use of remittances for operational needs (e.g., employee payments) without benefit to the Respondent. Having recorded and accepted the undertaking, the HC disposed of the petition on that basis, subject to enforcement of the undertaking and any future application for variation or recall.
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