Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Cash can fall within the statutory meaning of "property" where it is a movable asset used for acquisition or transfer of value. On the facts, routing demonetised cash through a third party's bank account and receiving it back through banking channels satisfied the ingredients of a benami transaction because one person held the property while another provided the consideration and benefited from the transfer. The Tribunal held that immediate retransfer did not take the arrangement outside the Act. It also modified the provisional attachment by restricting it to the reduced amount after giving credit for sums already paid under the disclosure scheme and deposited in interest-free bonds, while permitting tracing and attachment of any remaining balance if unavailable in the appellant's account.
Cash can fall within the statutory meaning of "property" where it is a movable asset used for acquisition or transfer of value. On the facts, routing demonetised cash through a third party's bank account and receiving it back through banking channels satisfied the ingredients of a benami transaction because one person held the property while another provided the consideration and benefited from the transfer. The Tribunal held that immediate retransfer did not take the arrangement outside the Act. It also modified the provisional attachment by restricting it to the reduced amount after giving credit for sums already paid under the disclosure scheme and deposited in interest-free bonds, while permitting tracing and attachment of any remaining balance if unavailable in the appellant's account.
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