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 allowed the appeal, set aside the adjudicating authority's order dated 18.08.2020, and declared the attached immovable property as "benami property" under Section 2(9)(A) PBPT Act. It held that purported share application money later shown as unsecured, interest-free loans, without allotment of shares, security, interest, loan agreement, or acknowledgments within limitation, rendered the alleged debt time-barred and unreal, indicating a benami arrangement to route funds for property purchase. The right of Kotak Mahindra Bank, which had granted an overdraft facility prior to the provisional attachment and without knowledge of PBPT proceedings, was expressly protected. The DCIT was given liberty to initiate separate proceedings against the subsequent beneficial owner.
AT allowed the appeal, set aside the adjudicating authority's order dated 18.08.2020, and declared the attached immovable property as "benami property" under Section 2(9)(A) PBPT Act. It held that purported share application money later shown as unsecured, interest-free loans, without allotment of shares, security, interest, loan agreement, or acknowledgments within limitation, rendered the alleged debt time-barred and unreal, indicating a benami arrangement to route funds for property purchase. The right of Kotak Mahindra Bank, which had granted an overdraft facility prior to the provisional attachment and without knowledge of PBPT proceedings, was expressly protected. The DCIT was given liberty to initiate separate proceedings against the subsequent beneficial owner.
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