Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Section 2(9)(D) treats a transaction as benami where the person providing consideration is untraceable or fictitious. For immovable property, claimed loans may fail to establish the source of consideration where alleged lenders' financial capacity and fund sources are unproved, supporting loan documentation is absent, and no repayment or interest payment is evidenced. Failure to explain the balance consideration and validation fee can further support the conclusion that the consideration provider was untraceable or fictitious. On these stated grounds, provisional attachment of the land as benami property was confirmed and the appeal was dismissed.
Section 2(9)(D) treats a transaction as benami where the person providing consideration is untraceable or fictitious. For immovable property, claimed loans may fail to establish the source of consideration where alleged lenders' financial capacity and fund sources are unproved, supporting loan documentation is absent, and no repayment or interest payment is evidenced. Failure to explain the balance consideration and validation fee can further support the conclusion that the consideration provider was untraceable or fictitious. On these stated grounds, provisional attachment of the land as benami property was confirmed and the appeal was dismissed.
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