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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Interpretation of "fiduciary capacity" in the context of benami transactions. It clarifies that fiduciary capacity cannot be used as an exception in all circumstances, particularly when property is transferred for illegal purposes or when a concluded contract passes title to others. The fiduciary exception applies only in cases where money is kept with another person on trust for safe custody, and not where there is a conflict of interest or profit motive. The Adjudicating Authority's analysis of witness statements and the Income Tax assessment supporting the respondent's position are also mentioned. The key legal principles regarding benami transactions and the scope of the fiduciary capacity exception are elucidated.
Interpretation of "fiduciary capacity" in the context of benami transactions. It clarifies that fiduciary capacity cannot be used as an exception in all circumstances, particularly when property is transferred for illegal purposes or when a concluded contract passes title to others. The fiduciary exception applies only in cases where money is kept with another person on trust for safe custody, and not where there is a conflict of interest or profit motive. The Adjudicating Authority's analysis of witness statements and the Income Tax assessment supporting the respondent's position are also mentioned. The key legal principles regarding benami transactions and the scope of the fiduciary capacity exception are elucidated.
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