Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
