Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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Shares transferred under a MoU and share purchase agreement were held to be benami property because the arrangement was not a genuine arm's length commercial deal. The transferor had already funded the original acquisition, the transferee paid only a negligible upfront amount, and the balance depended on a future sale that never materialised. The lien and pledge terms kept effective control with the transferor, while the transferee lacked independent financial capacity and used dividends from the same shares to make payment. On these facts, both limbs of Section 2(9)(A) were satisfied, so the Adjudicating Authority erred in treating the transfer as genuine; the provisional attachment was restored.
Shares transferred under a MoU and share purchase agreement were held to be benami property because the arrangement was not a genuine arm's length commercial deal. The transferor had already funded the original acquisition, the transferee paid only a negligible upfront amount, and the balance depended on a future sale that never materialised. The lien and pledge terms kept effective control with the transferor, while the transferee lacked independent financial capacity and used dividends from the same shares to make payment. On these facts, both limbs of Section 2(9)(A) were satisfied, so the Adjudicating Authority erred in treating the transfer as genuine; the provisional attachment was restored.
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