Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
