Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Verification showed the seized jewellery were not held as benami by the alleged benamidar; subsequent provenance submissions and disclosures were accepted as genuine, including aggregate disclosure by the related person of funds and sales proceeds. The Tribunal applied provenance and verification evidence to reject the benami characterisation and held that the provisional attachment under the PBPTA could not be sustained; accordingly the attachment was set aside and the appeal allowed.
Verification showed the seized jewellery were not held as benami by the alleged benamidar; subsequent provenance submissions and disclosures were accepted as genuine, including aggregate disclosure by the related person of funds and sales proceeds. The Tribunal applied provenance and verification evidence to reject the benami characterisation and held that the provisional attachment under the PBPTA could not be sustained; accordingly the attachment was set aside and the appeal allowed.
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