Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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