Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Cash is treated as property under the Act, and routing demonetised cash through another person's bank account and back through banking channels can amount to a benami arrangement if the alleged business deal is not genuine. The Tribunal relied on inconsistencies in stock records, invoices, bank entries and the claimed gold sale, and noted the absence of purchaser KYC, PAN and reliable proof of delivery through the broker; it treated the broker's affidavit as insufficient. It also rejected objections on non-examination of the alleged account operator and on cross-examination, finding the person untraceable and no prejudice shown. The attachment was upheld and the appeal dismissed.
Cash is treated as property under the Act, and routing demonetised cash through another person's bank account and back through banking channels can amount to a benami arrangement if the alleged business deal is not genuine. The Tribunal relied on inconsistencies in stock records, invoices, bank entries and the claimed gold sale, and noted the absence of purchaser KYC, PAN and reliable proof of delivery through the broker; it treated the broker's affidavit as insufficient. It also rejected objections on non-examination of the alleged account operator and on cross-examination, finding the person untraceable and no prejudice shown. The attachment was upheld and the appeal dismissed.
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