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 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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