Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Enforceability of a foreign judgment under the Code of Civil Procedure turned on reciprocity and exceptions to enforcement: the United Kingdom was a reciprocating territory and the English High Court decree was from a superior court, so the decree is executable. The court held objections based on alleged FEMA or RBI non-compliance cannot be raised for the first time in India where such issues were not argued before the foreign court; damages and interest awarded for breach of contract by a competent foreign court are not subject to FEMA/RBI ceilings or Master Direction-ECB limits, and the foreign decree did not fall within exceptions to enforcement.
Enforceability of a foreign judgment under the Code of Civil Procedure turned on reciprocity and exceptions to enforcement: the United Kingdom was a reciprocating territory and the English High Court decree was from a superior court, so the decree is executable. The court held objections based on alleged FEMA or RBI non-compliance cannot be raised for the first time in India where such issues were not argued before the foreign court; damages and interest awarded for breach of contract by a competent foreign court are not subject to FEMA/RBI ceilings or Master Direction-ECB limits, and the foreign decree did not fall within exceptions to enforcement.
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