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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The AT upheld the validity of the provisional attachment order under the PBPT Act over cash seized from the appellant, holding that unaccounted cash qualifies as movable benami property under Section 2(26) and Section 2(8) of the Act. The tribunal rejected the appellant's contention that a benami transaction requires three parties, affirming that only a benamidar and beneficial owner are necessary. The appellant's failure to substantiate the source of Rs. 1.84 crore seized and reliance on inconsistent statements, including under Section 131 of the Income Tax Act, led to the conclusion that Section 2(9)(D) applies. Filing of ITRs was held insufficient to exclude applicability of the PBPT Act, as unexplained income remains subject to confiscation irrespective of tax compliance. Consequently, the attachment and proceedings under the PBPT Act were affirmed against the appellant.
The AT upheld the validity of the provisional attachment order under the PBPT Act over cash seized from the appellant, holding that unaccounted cash qualifies as movable benami property under Section 2(26) and Section 2(8) of the Act. The tribunal rejected the appellant's contention that a benami transaction requires three parties, affirming that only a benamidar and beneficial owner are necessary. The appellant's failure to substantiate the source of Rs. 1.84 crore seized and reliance on inconsistent statements, including under Section 131 of the Income Tax Act, led to the conclusion that Section 2(9)(D) applies. Filing of ITRs was held insufficient to exclude applicability of the PBPT Act, as unexplained income remains subject to confiscation irrespective of tax compliance. Consequently, the attachment and proceedings under the PBPT Act were affirmed against the appellant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
