Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Alleged benami sale of agricultural land was upheld where the payment trail showed the beneficial owner - not the named transferee - furnished consideration, negating a fiduciary or temporary holding claim; outcome: attachment confirmed and appeal dismissed. Reconstitution and partnership documents lacked genuine participation or signatures by the named transferee, supporting that the transferee held title as a benamidar in name only, and financial records showed no capacity to fund the purchase, reinforcing benami inference. On these bases the tribunal found the statutory definition of benami property satisfied and declined to disturb the impugned order confirming provisional attachment.
Alleged benami sale of agricultural land was upheld where the payment trail showed the beneficial owner - not the named transferee - furnished consideration, negating a fiduciary or temporary holding claim; outcome: attachment confirmed and appeal dismissed. Reconstitution and partnership documents lacked genuine participation or signatures by the named transferee, supporting that the transferee held title as a benamidar in name only, and financial records showed no capacity to fund the purchase, reinforcing benami inference. On these bases the tribunal found the statutory definition of benami property satisfied and declined to disturb the impugned order confirming provisional attachment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
