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...
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
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