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 affirmed the Adjudicating Authority's finding that the cash seized from the appellant constituted benami property under the PBPT Act. The appellant failed to substantiate ownership or legitimate source of the Rs. 67,00,000/- cash, and the purported transactions and GST filings were deemed fabricated. CCTV evidence contradicted the appellant's claim of extensive sales, undermining the credibility of the bill book entries. The appellant's inconsistent statements under the Income Tax Act further weakened his position. The absence of proof establishing any fiduciary relationship precluded relief under the Act. The Tribunal held that the appellant could not rebut the presumption of benami ownership, and no error was found in the factual and legal conclusions of the Adjudicating Authority. Consequently, the appeal was dismissed, upholding the provisional attachment order.
The AT affirmed the Adjudicating Authority's finding that the cash seized from the appellant constituted benami property under the PBPT Act. The appellant failed to substantiate ownership or legitimate source of the Rs. 67,00,000/- cash, and the purported transactions and GST filings were deemed fabricated. CCTV evidence contradicted the appellant's claim of extensive sales, undermining the credibility of the bill book entries. The appellant's inconsistent statements under the Income Tax Act further weakened his position. The absence of proof establishing any fiduciary relationship precluded relief under the Act. The Tribunal held that the appellant could not rebut the presumption of benami ownership, and no error was found in the factual and legal conclusions of the Adjudicating Authority. Consequently, the appeal was dismissed, upholding the provisional attachment order.
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