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 held that a benami transaction, as defined under the Act, occurred. Noting material inconsistencies in the appellant's pleadings and lacunae in documentary proof - including contradictory dates, evolving averments, illegible bank statements, non-filing of relevant ITRs and bank accounts, and unexplained routing of funds through third parties - the Tribunal concluded that the record did not permit final resolution on whether the attached properties derived from the original benami proceeds. The AT set aside the impugned order and remitted the matter to the Ld. Adjudicating Authority under the PBPT Act for de novo adjudication, directing a fresh hearing and fuller fact-finding on the provenance of funds.
AT held that a benami transaction, as defined under the Act, occurred. Noting material inconsistencies in the appellant's pleadings and lacunae in documentary proof - including contradictory dates, evolving averments, illegible bank statements, non-filing of relevant ITRs and bank accounts, and unexplained routing of funds through third parties - the Tribunal concluded that the record did not permit final resolution on whether the attached properties derived from the original benami proceeds. The AT set aside the impugned order and remitted the matter to the Ld. Adjudicating Authority under the PBPT Act for de novo adjudication, directing a fresh hearing and fuller fact-finding on the provenance of funds.
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