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...
Reopening of assessment challenged on the ground that reasons to believe lacked a live evidentiary link between seized materials and the assessee; the AO relied on statements and a brokers register suggesting a cash on money component and a unit rate, but those documents did not name the co-owner or the assessee. The AOs computation accepted the assessees 30% share, yet the asserted intent to sell the entire plot earlier conflicted with subsequent gift transactions by the co-owner. For lack of independent corroborative material connecting the assessee to the alleged on-money transaction, the impugned notice was quashed.
Reopening of assessment challenged on the ground that reasons to believe lacked a live evidentiary link between seized materials and the assessee; the AO relied on statements and a brokers register suggesting a cash on money component and a unit rate, but those documents did not name the co-owner or the assessee. The AOs computation accepted the assessees 30% share, yet the asserted intent to sell the entire plot earlier conflicted with subsequent gift transactions by the co-owner. For lack of independent corroborative material connecting the assessee to the alleged on-money transaction, the impugned notice was quashed.
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