Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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The third limb of a benami transaction, requiring property to be held for the beneficial owner's future benefit, carries no fixed time limit and need not be established when provisional attachment is made. Provisional attachment may occur immediately to prevent alienation or transfer. Funds supplied by the beneficial owner for relatives' property purchases, coupled with their failure to substantiate independent income or a documented loan arrangement, supported treatment of the transactions as benami. Love and affection did not establish a genuine loan explanation where no supporting evidence existed. The transactions were treated as benami, and the confirmation of provisional attachment was sustained.
The third limb of a benami transaction, requiring property to be held for the beneficial owner's future benefit, carries no fixed time limit and need not be established when provisional attachment is made. Provisional attachment may occur immediately to prevent alienation or transfer. Funds supplied by the beneficial owner for relatives' property purchases, coupled with their failure to substantiate independent income or a documented loan arrangement, supported treatment of the transactions as benami. Love and affection did not establish a genuine loan explanation where no supporting evidence existed. The transactions were treated as benami, and the confirmation of provisional attachment was sustained.
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