Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Cash can fall within the wide definition of property under the PBPT Act, and where funds are transferred through entities controlled by another person and later routed back, both the transfer and temporary holding may satisfy section 2(9)(A); the routed entities are treated as benamidars and the provider as beneficial owner. Disclosure in an income-tax return or payment of tax does not, by itself, bar PBPT proceedings because the Act operates alongside the Income-tax Act and serves a distinct confiscatory purpose. Where tax has already been paid on the routed amount, the attachable benami property may be reduced to that extent. In a running business, transformed assets such as stock and receivables may remain attachable as converted form of benami property.
Cash can fall within the wide definition of property under the PBPT Act, and where funds are transferred through entities controlled by another person and later routed back, both the transfer and temporary holding may satisfy section 2(9)(A); the routed entities are treated as benamidars and the provider as beneficial owner. Disclosure in an income-tax return or payment of tax does not, by itself, bar PBPT proceedings because the Act operates alongside the Income-tax Act and serves a distinct confiscatory purpose. Where tax has already been paid on the routed amount, the attachable benami property may be reduced to that extent. In a running business, transformed assets such as stock and receivables may remain attachable as converted form of benami property.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
