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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AT determined that a gold purchase transaction of Rs. 1 Crore constituted a benami transaction under PBPTA. The transaction involved RTGS transfer from A's account to firm H, but gold delivery was made to M instead of A. Despite having A's signed invoice received through M, the appellant failed to establish direct delivery to A. Several suspicious elements emerged: cash deposit by non-account holder A, involvement of M who was partner in appellant's other firm B, subsequent closure of H's bank account with proceeds transferred to B where M was also partner. The appellant's claim of good faith was rejected due to irregular business practices and unexplained circumstances surrounding the transaction. The pattern of fund transfer, delivery arrangements, and business relationships indicated deliberate circumvention of normal procedures. Appeal dismissed.
AT determined that a gold purchase transaction of Rs. 1 Crore constituted a benami transaction under PBPTA. The transaction involved RTGS transfer from A's account to firm H, but gold delivery was made to M instead of A. Despite having A's signed invoice received through M, the appellant failed to establish direct delivery to A. Several suspicious elements emerged: cash deposit by non-account holder A, involvement of M who was partner in appellant's other firm B, subsequent closure of H's bank account with proceeds transferred to B where M was also partner. The appellant's claim of good faith was rejected due to irregular business practices and unexplained circumstances surrounding the transaction. The pattern of fund transfer, delivery arrangements, and business relationships indicated deliberate circumvention of normal procedures. Appeal dismissed.
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