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 confirmed seized cash of Rs. 98.93 crores and 166.27 kg gold bullion as benami property under Section 2(9)(D) of PBPTA, overturning the Adjudicating Authority's decision. The Tribunal found the respondent firm's explanation regarding unrecorded sand sale proceeds unconvincing, particularly noting the timing of seizures post-demonetization and simultaneous filing of ITRs for two assessment years. Partners' contradictory statements and retractions undermined credibility. The substantial unaccounted assets, absence from regular books, and lack of proper business records indicated benami transactions where respondent merely lent their name while concealing actual beneficial owners. Appeal allowed, provisional attachment order upheld.
AT confirmed seized cash of Rs. 98.93 crores and 166.27 kg gold bullion as benami property under Section 2(9)(D) of PBPTA, overturning the Adjudicating Authority's decision. The Tribunal found the respondent firm's explanation regarding unrecorded sand sale proceeds unconvincing, particularly noting the timing of seizures post-demonetization and simultaneous filing of ITRs for two assessment years. Partners' contradictory statements and retractions undermined credibility. The substantial unaccounted assets, absence from regular books, and lack of proper business records indicated benami transactions where respondent merely lent their name while concealing actual beneficial owners. Appeal allowed, provisional attachment order upheld.
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