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    International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Benami Property

Income-tax search material can be relied on in benami...

Benami transaction findings upheld on search material, routed accommodation entries, and corroborated statements despite retraction

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Benami Property April 14, 2026 Case Laws AT
Income-tax search material can be relied on in benami proceedings absent any statutory bar, and the fact that the material originated in tax proceedings does not require a separate independent enquiry as a precondition to benami adjudication. The Tribunal held that routed accommodation entries, supported by connected statements and corroborating electronic records, established a benami transaction; retraction alone did not displace those statements where no satisfactory basis for retraction was shown. It also held that income-tax assessment and benami adjudication operate in distinct fields, so tax treatment of undisclosed income does not preclude a parallel benami finding. The provisional attachment was therefore sustained and the appeals were dismissed.

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Acts Income Tax