Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Benami transaction findings were sustained where deposits and transfers arose from demonetization-linked routing and accommodation entries, and no credible source of funds or business activity was shown; the fiduciary-capacity exception was rejected because receipt of funds lacked any element of repayment. Creditworthiness and income-tax return analysis of the entities showed inability to account for large cash receipts, and conflicting statements under section 131 were noted. Operative effect: the adjudicating authority's conclusion that the transaction was benami was upheld and the appeal dismissed.
Benami transaction findings were sustained where deposits and transfers arose from demonetization-linked routing and accommodation entries, and no credible source of funds or business activity was shown; the fiduciary-capacity exception was rejected because receipt of funds lacked any element of repayment. Creditworthiness and income-tax return analysis of the entities showed inability to account for large cash receipts, and conflicting statements under section 131 were noted. Operative effect: the adjudicating authority's conclusion that the transaction was benami was upheld and the appeal dismissed.
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