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...
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
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