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...
Issue 1 - Unexplained investment under section 69A: tribunal found ledger and monthly summaries of proprietor's drawings (narrating cash withdrawals used to purchase the site) constituted prima facie source for the cash payments, though these records were not produced before the AO; consequence: matter remitted to the AO to consider the documents filed before the tribunal (and any further evidence) and decide in accordance with law after hearing the assessee. Issue 2 - Net-profit determination: AO's adoption of 8% standard profit was unsupported, whereas audited books and industry comparables justified the declared 7% margin; consequence: addition confirmed by lower authorities set aside and appeal allowed. - ITAT
Issue 1 - Unexplained investment under section 69A: tribunal found ledger and monthly summaries of proprietor's drawings (narrating cash withdrawals used to purchase the site) constituted prima facie source for the cash payments, though these records were not produced before the AO; consequence: matter remitted to the AO to consider the documents filed before the tribunal (and any further evidence) and decide in accordance with law after hearing the assessee. Issue 2 - Net-profit determination: AO's adoption of 8% standard profit was unsupported, whereas audited books and industry comparables justified the declared 7% margin; consequence: addition confirmed by lower authorities set aside and appeal allowed. - ITAT
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