Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Provisional attachment of the property was confirmed under the PBPT Act as the transaction falls within the scope of benami property under Section 2(9)(A); the appellant failed to explain sources of funds, did not produce original lease evidence and adverse inference was drawn for non-production, supporting IO findings of fabrication. Beneficial ownership remains under investigation-IO to re-investigate whether the beneficial owner includes the named individual, his son, and/or a company-so the property is not to be released. The Tribunal may modify AA orders under Section 46(4)(e); appeal by the benamidar is dismissed.
Provisional attachment of the property was confirmed under the PBPT Act as the transaction falls within the scope of benami property under Section 2(9)(A); the appellant failed to explain sources of funds, did not produce original lease evidence and adverse inference was drawn for non-production, supporting IO findings of fabrication. Beneficial ownership remains under investigation-IO to re-investigate whether the beneficial owner includes the named individual, his son, and/or a company-so the property is not to be released. The Tribunal may modify AA orders under Section 46(4)(e); appeal by the benamidar is dismissed.
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