Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Benami proceedings involving a fictitious-name transaction turn on cumulative evidence rather than the supplier's failure to file tax returns alone. The alleged supplier's absence from its stated address, unserved notices, inconsistent GST business description, untraceable bank account, and lack of credible proof of supply, delivery, payment, or accounting were identified as sufficient to discharge the initial burden; the appellants did not rebut it. The transaction was therefore treated as benami under Section 2(9)(B). In a fictitious transaction, the routed amount may be regarded as returning to the beneficial owner, permitting attachment in that owner's account rather than requiring attachment only from a benamidar. The provisional attachment and related findings were upheld.
Benami proceedings involving a fictitious-name transaction turn on cumulative evidence rather than the supplier's failure to file tax returns alone. The alleged supplier's absence from its stated address, unserved notices, inconsistent GST business description, untraceable bank account, and lack of credible proof of supply, delivery, payment, or accounting were identified as sufficient to discharge the initial burden; the appellants did not rebut it. The transaction was therefore treated as benami under Section 2(9)(B). In a fictitious transaction, the routed amount may be regarded as returning to the beneficial owner, permitting attachment in that owner's account rather than requiring attachment only from a benamidar. The provisional attachment and related findings were upheld.
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