Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
The dominant issue was whether the initiating officer validly recorded "reasons to believe" before issuing notice under section 24(1) for provisional attachment under the benami law. It was held that the reasons were recorded in writing and duly disclosed within the show cause notice; there is no statutory requirement to separately furnish a copy of such reasons, and the notice reflected analysis of statements and bank records, so the challenge failed. On merits, receipt of demonetised cash in the appellant's bank account, followed by RTGS transfers to beneficiaries, was treated as strong evidence of a benami arrangement, and the claimed business explanation remained unsubstantiated; the appeal was dismissed. - AT
The dominant issue was whether the initiating officer validly recorded "reasons to believe" before issuing notice under section 24(1) for provisional attachment under the benami law. It was held that the reasons were recorded in writing and duly disclosed within the show cause notice; there is no statutory requirement to separately furnish a copy of such reasons, and the notice reflected analysis of statements and bank records, so the challenge failed. On merits, receipt of demonetised cash in the appellant's bank account, followed by RTGS transfers to beneficiaries, was treated as strong evidence of a benami arrangement, and the claimed business explanation remained unsubstantiated; the appeal was dismissed. - AT
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