Additions of income earned - Taxable Person - Land transactions...

Additions of income earned - Taxable Person - Land transactions facilitated by a financier but executed in another's name - Taxable in the hands of company or Individual - Protective Assessment in the Hands of Individual - Burden of proof - The tribunal determined that the economic substance of the transactions indicated that Individual acted as a mere financier or conduit rather than as a principal participant. It concluded that the income should not be assessed in the hands of Such Individual as he did not exercise control over the land or the transactions beyond merely being the named party in the documentation. - This case highlights the complexities involved in transactions where the nominal parties do not reflect the true nature of the economic interests at stake.

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