Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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Benami characterisation of land acquired in an apparent purchaser's name rested on cumulative evidence of limited financial means, a statement that the sale deed was signed at the beneficial owner's behest, documented nexus between them, and proof of the payment source. A later retraction affidavit lacked support and was treated as unreliable because it conflicted with the sale deed, was delayed without explanation, and referred to an implausible future event. The land was treated as benami property, sustaining confirmation of provisional attachment.
Benami characterisation of land acquired in an apparent purchaser's name rested on cumulative evidence of limited financial means, a statement that the sale deed was signed at the beneficial owner's behest, documented nexus between them, and proof of the payment source. A later retraction affidavit lacked support and was treated as unreliable because it conflicted with the sale deed, was delayed without explanation, and referred to an implausible future event. The land was treated as benami property, sustaining confirmation of provisional attachment.
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