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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AT dismissed the appeal and affirmed that Rs. 92,00,000 constituted benami property under the PBPT Act. The Tribunal found the cash, though briefly deposited in the alleged benamidar's bank account, was transferred to and held for the benefit of the alleged beneficial owner company, satisfying the statutory requisites of a benami transaction. The fiduciary-capacity exception was rejected because the purported fiduciary relationship was not established: the individual was an independent businessman, not an employee, and admitted the cash purpose to defeat demonetisation. The AT further held cash falls within the definition of "property" under Section 2(26) of the PBPT Act and consequently dismissed the appeal.
AT dismissed the appeal and affirmed that Rs. 92,00,000 constituted benami property under the PBPT Act. The Tribunal found the cash, though briefly deposited in the alleged benamidar's bank account, was transferred to and held for the benefit of the alleged beneficial owner company, satisfying the statutory requisites of a benami transaction. The fiduciary-capacity exception was rejected because the purported fiduciary relationship was not established: the individual was an independent businessman, not an employee, and admitted the cash purpose to defeat demonetisation. The AT further held cash falls within the definition of "property" under Section 2(26) of the PBPT Act and consequently dismissed the appeal.
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