Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Circumstantial evidence of routed bank credits, cash deposits before registration, and unexplained transferors' funds was sufficient to establish a prima facie benami transaction in immovable properties. The appellants failed to show an independent source of consideration for the purchases, and their disclosed income was inadequate to fund the acquisitions. Statements under the PMLA and surrounding material supported accommodation entries and cash repayment arrangements. Even without reliance on the alleged beneficial owner's role, the benami case survived because the benamidars themselves could not explain the source of funds. The provisional attachment was therefore sustained and the appeals were dismissed.
Circumstantial evidence of routed bank credits, cash deposits before registration, and unexplained transferors' funds was sufficient to establish a prima facie benami transaction in immovable properties. The appellants failed to show an independent source of consideration for the purchases, and their disclosed income was inadequate to fund the acquisitions. Statements under the PMLA and surrounding material supported accommodation entries and cash repayment arrangements. Even without reliance on the alleged beneficial owner's role, the benami case survived because the benamidars themselves could not explain the source of funds. The provisional attachment was therefore sustained and the appeals were dismissed.
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