Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Appellant Directorate attached 29 properties in a benami transaction case. Adjudicating Authority excluded properties bought in the name of a family member, shifting burden to show consideration. Appellant argued against the finding, citing facts and legal definition of benami transaction. It was found that properties exceeded earnings, acquired with illicit income. Appellate Tribunal allowed appeal, confirming attachment of some properties pending review, but setting aside order for others due to inadequate consideration and benefitting from corruption.
Appellant Directorate attached 29 properties in a benami transaction case. Adjudicating Authority excluded properties bought in the name of a family member, shifting burden to show consideration. Appellant argued against the finding, citing facts and legal definition of benami transaction. It was found that properties exceeded earnings, acquired with illicit income. Appellate Tribunal allowed appeal, confirming attachment of some properties pending review, but setting aside order for others due to inadequate consideration and benefitting from corruption.
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