Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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.