Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
Tribunal held that estimating undisclosed income by applying a percentage to sales turnover was unsustainable where books showed purchases and sales, payments passed through banking channels, no cash introductions were proved, and AO did not justify the rate; consequently additions based on turnover estimation were deleted. The tribunal upheld allowability of depreciation and indirect/finance expenses because expenditures were recorded, payments evidenced, and no material showed expenses were fictitious. Additions treating intra group unsecured loans as unexplained cash credits were deleted where creditor identity and creditworthiness, ledger entries, repayments, prior advances and bank records supported the transactions.
Tribunal held that estimating undisclosed income by applying a percentage to sales turnover was unsustainable where books showed purchases and sales, payments passed through banking channels, no cash introductions were proved, and AO did not justify the rate; consequently additions based on turnover estimation were deleted. The tribunal upheld allowability of depreciation and indirect/finance expenses because expenditures were recorded, payments evidenced, and no material showed expenses were fictitious. Additions treating intra group unsecured loans as unexplained cash credits were deleted where creditor identity and creditworthiness, ledger entries, repayments, prior advances and bank records supported the transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
