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 that statements recorded under s.19(1) of the Act of 1988, taken on oath, were admissible; the appellant (A) failed to establish provenance of cash recovered from him, disowned it at seizure, and later attributed it to B, who denied knowledge, leaving the beneficial owner unknown. Proceedings under s.2(9)(c) were correctly instituted and the Adjudicating Authority's benami finding was sustained. The Tribunal noted uncertainties regarding any subsequent Income-tax assessment but found no merit to disturb the impugned orders. The appeal is dismissed, with the contested cash treated as undisclosed/benami property and the appellant's challenge rejected.
The AT upheld that statements recorded under s.19(1) of the Act of 1988, taken on oath, were admissible; the appellant (A) failed to establish provenance of cash recovered from him, disowned it at seizure, and later attributed it to B, who denied knowledge, leaving the beneficial owner unknown. Proceedings under s.2(9)(c) were correctly instituted and the Adjudicating Authority's benami finding was sustained. The Tribunal noted uncertainties regarding any subsequent Income-tax assessment but found no merit to disturb the impugned orders. The appeal is dismissed, with the contested cash treated as undisclosed/benami property and the appellant's challenge rejected.
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