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...
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Benami acquisition of shares was established through the alleged benamidar's lack of economic capacity and genuine operations, indirect funding from entities connected to the beneficial owner, unsupported commercial explanations, and the beneficial owner's effective control. Applying indicia including the source of consideration, parties' relationship and surrounding circumstances, the Tribunal confirmed attachment of the identified shares as benami property. However, attachment could extend only to shares specified in the show-cause notice, provisional attachment order and impugned order. Freezing additional shares in the demat account without material linking them to the benami proceedings was impermissible, and their release to the rightful owner was directed.
Benami acquisition of shares was established through the alleged benamidar's lack of economic capacity and genuine operations, indirect funding from entities connected to the beneficial owner, unsupported commercial explanations, and the beneficial owner's effective control. Applying indicia including the source of consideration, parties' relationship and surrounding circumstances, the Tribunal confirmed attachment of the identified shares as benami property. However, attachment could extend only to shares specified in the show-cause notice, provisional attachment order and impugned order. Freezing additional shares in the demat account without material linking them to the benami proceedings was impermissible, and their release to the rightful owner was directed.
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