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...
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
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