Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
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