SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Benami character under Section 2(9)(A) depends on the real relationship between consideration, holding and the direct or indirect benefit of the person providing funds, rather than transaction form. Bank funds and their proceeds may constitute property. A cash-to-bank trail through entities controlled by an alleged benamidar, supported by a sworn statement and surrounding commercial circumstances, may outweigh invoices and ledgers lacking independent substantiation. Procedural fairness requires disclosure of relied-upon material and a meaningful opportunity to respond; denial of cross-examination requires demonstrable prejudice. Provisional attachment remains subject to adjudication, hearing and appeal, while temporal application of amended definitions turns on whether property was transferred or continued to be held after commencement.
Benami character under Section 2(9)(A) depends on the real relationship between consideration, holding and the direct or indirect benefit of the person providing funds, rather than transaction form. Bank funds and their proceeds may constitute property. A cash-to-bank trail through entities controlled by an alleged benamidar, supported by a sworn statement and surrounding commercial circumstances, may outweigh invoices and ledgers lacking independent substantiation. Procedural fairness requires disclosure of relied-upon material and a meaningful opportunity to respond; denial of cross-examination requires demonstrable prejudice. Provisional attachment remains subject to adjudication, hearing and appeal, while temporal application of amended definitions turns on whether property was transferred or continued to be held after commencement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
