Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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.
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