Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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Provisional attachment of the motor vehicle was confirmed because the money trail linked its purchase to compensation arising from land earlier acquired in the name of the benamidar with funds provided by the alleged beneficial owner. The Tribunal relied on the admitted employment relationship, the benamidar's sworn admission that the land had been purchased in his name by the beneficial owner, the absence of any proved independent source of funds, and recovery of the vehicle registration document from the beneficial owner. On these facts, the claim that the vehicle was bought from the benamidar's own funds was rejected, and the challenge to its benami character failed.
Provisional attachment of the motor vehicle was confirmed because the money trail linked its purchase to compensation arising from land earlier acquired in the name of the benamidar with funds provided by the alleged beneficial owner. The Tribunal relied on the admitted employment relationship, the benamidar's sworn admission that the land had been purchased in his name by the beneficial owner, the absence of any proved independent source of funds, and recovery of the vehicle registration document from the beneficial owner. On these facts, the claim that the vehicle was bought from the benamidar's own funds was rejected, and the challenge to its benami character failed.
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