Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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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