Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
