Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Statements recorded under the Income Tax Act were held usable in benami proceedings because the two statutes operate in allied fields, and cross-examination was not treated as an automatic right under the Benami Act. The Tribunal found those statements corroborated by shareholding patterns, effective control of the companies by Mahaveer Lunia and his family, recovery of property lists from his residence, and the appellants' failure to prove lawful sources of funds. It further held that the companies functioned as fronts and the ingredients of benami transaction were satisfied, so the provisional attachment was confirmed and the appeals were dismissed.
Statements recorded under the Income Tax Act were held usable in benami proceedings because the two statutes operate in allied fields, and cross-examination was not treated as an automatic right under the Benami Act. The Tribunal found those statements corroborated by shareholding patterns, effective control of the companies by Mahaveer Lunia and his family, recovery of property lists from his residence, and the appellants' failure to prove lawful sources of funds. It further held that the companies functioned as fronts and the ingredients of benami transaction were satisfied, so the provisional attachment was confirmed and the appeals were dismissed.
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