Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Section 2(9)(C) of the Prohibition of Benami Property Transactions Act requires the purported owner to be unaware of, or deny knowledge of, ownership. Acknowledgements by alleged benamidars during cross-examination that they knew of share allotments and buy-backs, and received the consideration in their bank accounts, prevent the transactions from meeting that requirement. Such acknowledgements prevail over conflicting statements made in income-tax proceedings. Potential tax evasion reflected in trade-payable entries does not, by itself, establish a benami transaction. Consequently, provisional attachment cannot be confirmed where the statutory knowledge requirement is not satisfied.
Section 2(9)(C) of the Prohibition of Benami Property Transactions Act requires the purported owner to be unaware of, or deny knowledge of, ownership. Acknowledgements by alleged benamidars during cross-examination that they knew of share allotments and buy-backs, and received the consideration in their bank accounts, prevent the transactions from meeting that requirement. Such acknowledgements prevail over conflicting statements made in income-tax proceedings. Potential tax evasion reflected in trade-payable entries does not, by itself, establish a benami transaction. Consequently, provisional attachment cannot be confirmed where the statutory knowledge requirement is not satisfied.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4931 
