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...
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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