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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The AT dismissed the appeal of beneficial owners (bullion companies) who were found to have created backdated entries to conceal demonetized currency transactions exceeding Rs. 35 crores. Though appellants claimed legitimate gold transactions, FSL digital device reports contradicted this, showing they lacked sufficient gold stock to match RTGS transfers. The procedural objection regarding the 30-day notice period was rejected as appellants received adequate response time. However, the AT allowed appeals by abettors, holding that while they facilitated the benami transactions, their properties could not be attached under the 1988 Act as they were neither beneficial owners nor benamidars. The abettors remain subject to prosecution under Section 53 but their property attachments were set aside.
The AT dismissed the appeal of beneficial owners (bullion companies) who were found to have created backdated entries to conceal demonetized currency transactions exceeding Rs. 35 crores. Though appellants claimed legitimate gold transactions, FSL digital device reports contradicted this, showing they lacked sufficient gold stock to match RTGS transfers. The procedural objection regarding the 30-day notice period was rejected as appellants received adequate response time. However, the AT allowed appeals by abettors, holding that while they facilitated the benami transactions, their properties could not be attached under the 1988 Act as they were neither beneficial owners nor benamidars. The abettors remain subject to prosecution under Section 53 but their property attachments were set aside.
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