Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
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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