Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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