Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
AT dismissed the appeals and upheld the provisional attachment of the impugned property, finding a benami transaction under Section 2(9)(A). The Tribunal held that (1) consideration was transferred from the beneficial owner to the benamidar's account, (2) title was recorded in the benamidar, and (3) the acquisition was for the future benefit of the beneficial owner, satisfying all limbs of the statutory definition. Alleged loan evidence and a collaboration agreement were absent or unsubstantiated, and the belated induction of the benamidar's son into a partnership was seen as contrived. The AT found no error in the respondents' actions and affirmed the attachment.
AT dismissed the appeals and upheld the provisional attachment of the impugned property, finding a benami transaction under Section 2(9)(A). The Tribunal held that (1) consideration was transferred from the beneficial owner to the benamidar's account, (2) title was recorded in the benamidar, and (3) the acquisition was for the future benefit of the beneficial owner, satisfying all limbs of the statutory definition. Alleged loan evidence and a collaboration agreement were absent or unsubstantiated, and the belated induction of the benamidar's son into a partnership was seen as contrived. The AT found no error in the respondents' actions and affirmed the attachment.
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