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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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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