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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The dominant issue was whether the provisional attachment could be sustained by treating the land purchases as benami transactions under section 2(9)(A) of the 1988 Act as amended in 2016, despite the acquisitions preceding the amendment and objections regarding "transfer/held" and notice. The tribunal found admissions that properties were purchased in the benamidar's name while consideration flowed from the alleged beneficial owner, and that the appellants failed to substantiate any asserted onward transfer arrangement. Holding that the statutory ingredients of section 2(9)(A) stood satisfied on facts and finding no basis to interfere, the appeals were dismissed and the attachment upheld - AT
The dominant issue was whether the provisional attachment could be sustained by treating the land purchases as benami transactions under section 2(9)(A) of the 1988 Act as amended in 2016, despite the acquisitions preceding the amendment and objections regarding "transfer/held" and notice. The tribunal found admissions that properties were purchased in the benamidar's name while consideration flowed from the alleged beneficial owner, and that the appellants failed to substantiate any asserted onward transfer arrangement. Holding that the statutory ingredients of section 2(9)(A) stood satisfied on facts and finding no basis to interfere, the appeals were dismissed and the attachment upheld - AT
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