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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The AT upheld the Adjudicating Authority's finding that the appellant failed to establish legitimate sources of funds for acquiring the property, which was alleged to be benami. Despite the appellant's claim of income from sale of paddy and disclosed receipts, the financial records demonstrated insufficient funds to justify the purchase price. The appellant also failed to prove the alleged agricultural income. Evidence indicated the property was purchased to shield a third party from loan recovery proceedings, with the appellant acting as a nominee. The tribunal found the initial burden of proof sufficiently discharged by the respondents, and the appellant's efforts to demonstrate lawful source of funds were unpersuasive. Consequently, the impugned order declaring the property as benami was affirmed, and no interference was warranted.
The AT upheld the Adjudicating Authority's finding that the appellant failed to establish legitimate sources of funds for acquiring the property, which was alleged to be benami. Despite the appellant's claim of income from sale of paddy and disclosed receipts, the financial records demonstrated insufficient funds to justify the purchase price. The appellant also failed to prove the alleged agricultural income. Evidence indicated the property was purchased to shield a third party from loan recovery proceedings, with the appellant acting as a nominee. The tribunal found the initial burden of proof sufficiently discharged by the respondents, and the appellant's efforts to demonstrate lawful source of funds were unpersuasive. Consequently, the impugned order declaring the property as benami was affirmed, and no interference was warranted.
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