Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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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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