Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Under the PBPT Act, attachment can continue only against benami property held by a benamidar or beneficial owner; property cannot be attached merely because its owner is treated as an abettor unless the property itself is found to be benami. The Tribunal noted that the appellant had been proceeded against as beneficial owner initially, but the adjudication position shifted to Smt. Shital Soni as beneficial owner and the appellant as only an abettor. As there was no specific finding that the appellant's attached properties were benami, continuation of attachment was unsustainable. The attachment was set aside to that extent, while the appellant's exposure to consequences for abetment was left unaffected.
Under the PBPT Act, attachment can continue only against benami property held by a benamidar or beneficial owner; property cannot be attached merely because its owner is treated as an abettor unless the property itself is found to be benami. The Tribunal noted that the appellant had been proceeded against as beneficial owner initially, but the adjudication position shifted to Smt. Shital Soni as beneficial owner and the appellant as only an abettor. As there was no specific finding that the appellant's attached properties were benami, continuation of attachment was unsustainable. The attachment was set aside to that extent, while the appellant's exposure to consequences for abetment was left unaffected.
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