International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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Bank account credits were held to originate from a third party and the account functioned as a conduit; therefore the credited sums were not treated as the assessee's unexplained income. The Tribunal relied on bank statements, deposit-withdrawal patterns and admissions to conclude the assessee permitted use of his account for Shree Impex, with a different principal beneficiary. Because the assessee facilitated transactions and obtained a limited benefit, the Tribunal treated the correct tax consequence as assessable commission income and directed assessment of commission on the turnover routed through the account, applying the same reasoning to other identical assessment years.
Bank account credits were held to originate from a third party and the account functioned as a conduit; therefore the credited sums were not treated as the assessee's unexplained income. The Tribunal relied on bank statements, deposit-withdrawal patterns and admissions to conclude the assessee permitted use of his account for Shree Impex, with a different principal beneficiary. Because the assessee facilitated transactions and obtained a limited benefit, the Tribunal treated the correct tax consequence as assessable commission income and directed assessment of commission on the turnover routed through the account, applying the same reasoning to other identical assessment years.
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