Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
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Cash is movable property capable of being held benami. Where a beneficial owner supplies demonetised cash to a third party, who deposits it in that person's bank account and retransfers the funds through banking channels, the third party lends their name and holds the resulting bank balance for the provider's benefit. The cash constitutes consideration for the bank balance, and the retransfer evidences beneficial ownership; the duration of holding is immaterial. The transaction was treated as benami, with attachment limited to the remaining balance and the amount held in an interest-free bond, subject to tracing unavailable funds.
Cash is movable property capable of being held benami. Where a beneficial owner supplies demonetised cash to a third party, who deposits it in that person's bank account and retransfers the funds through banking channels, the third party lends their name and holds the resulting bank balance for the provider's benefit. The cash constitutes consideration for the bank balance, and the retransfer evidences beneficial ownership; the duration of holding is immaterial. The transaction was treated as benami, with attachment limited to the remaining balance and the amount held in an interest-free bond, subject to tracing unavailable funds.
Note: It is a system-generated summary and is for quick reference only.