CA Manoj K Tiwari welcomes you.

CA Manoj K Tiwari welcomes you

Section 56(2)(x)- Transfer for no/ inadequate consideration

Section 56. Income from other sources
Section 56 sub-section (2) In particular, and without prejudice to the generality of the provisions of sub-section (1), the following income shall be chargeable to income-tax under the head Income from other sources, namely: (x) where any person receives, in any previous year, from any person or persons on or after the 1st day of April, 2017,- (a) any sum of money, without consideration, the aggregate value of which exceeds fifty thousand rupees, the whole of the aggregate value of such sum; November 10, 2018  :

(b) any immovable property,-- without consideration, the stamp duty value of which exceeds fifty thousand rupees, the stamp duty value of such property; (B) for a consideration which is less than the stamp duty value of the property by an amount exceeding fifty thousand rupees, the stamp duty value of such property as exceeds such consideration: Provided that where the date of agreement fixing the amount of consideration for the transfer of immovable property and the date of registration are not the same, the stamp duty value on the date of agreement may be taken for the purposes of this sub-clause: November 10, 2018  :

Provided further that the provisions of the first proviso shall apply only in a case where the amount of consideration referred to therein, or a part thereof, has been paid by way of an account payee cheque or an account payee bank draft or by use of electronic clearing system through a bank account, on or before the date of agreement for transfer of such immovable property: Provided also that where the stamp duty value of immovable property is disputed by the assessee on grounds mentioned in sub-section (2) of section 50C, the Assessing Officer may refer the valuation of such property to a Valuation Officer, and the provisions of section 50C and sub-section (15) of section 155 shall, as far as may be, apply in relation to the stamp duty value of such property for the purpose of this sub-clause as they apply for valuation of capital asset under those sections; November 10, 2018  :

(c) any property, other than immovable property,-- without consideration, the aggregate fair market value of which exceeds fifty thousand rupees, the whole of the aggregate fair market value of such property; (B) for a consideration which is less than the aggregate fair market value of the property by an amount exceeding fifty thousand rupees, the aggregate fair market value of such property as exceeds such consideration: November 10, 2018  :

Summary of changes between old and present provisions
Particulars Section 56(2)(vii) Section 56(2)(viia) Section 56(2)(x) Persons covered Individual/ HUF CHC / Firm All the taxpayers as defined under 2(31) which includes Company, Firm, Individual/ HUF, AOP/ BOI, Trust etc Definition of property Immovable property being land or building or both, shares and securities, jewellery, archaeological collections, drawings, paintings, sculptures, any work of art, bullion Not applicable Same as section 56(2)(vii) Receipt of shares of CHC Covered Coverage of assets within the scope of sections Sum of money; and Capital assets being shares, securities, immovable properties, jewellery, archaeological collection, drawings, paintings, sculptures, any work of art or bullion Only shares of CHC November 10, 2018  :

Statutory carve out from section 56(2)(x)- Proviso to section 56(2)(x)
Sr No. Statutory carve out for recipient under section 56(2)(x) 1 Any property received from any relative 2 Any property received on occasion of marriage 3 Any property received by way of will or inheritance 4 Any property received in contemplation of death of the payer or donor 5 From any local authority as defined under explanation to section 10(20) 6 Any property received from the taxpayers mentioned under section 10(23C) 7 Any property received from or received by the trust registered under section 12A or 12AA November 10, 2018  :

Statutory carve out from section 56(2)(x)- Proviso to section 56(2)(x)
Sr No. Statutory carve out for recipient under section 56(2)(x) 8 Any property received by the taxpayer mentioned under section 10(23C)(iv),(v),(vi) and (via) 9 Any property received by way of following transfers: - Distribution of capital assets on total or partial partition of HUF - Tax neutral merger and demerger as mentioned under 47(vi), 47(via), 47(vib), 47(vic), 47(vid), 47(vii) - Other tax neutral re-organization specific to banking sectors [section 47 (viaa), (vica), (vicb)] Any property received by the trust from the transferor solely for the benefit of relatives of the transferor 10 Any property received by the trust from the transferor solely for the benefit of relatives of the transferor November 10, 2018  :

Key issues on/ scenarios under section 56(2)(x)
November 10, 2018  :

Meaning of ‘sum of money’ [Section 56(2)(x)(a)]
Subvention receipts by subsidiary from holding company Prior to introduction of section 56(2)(x) the Hon’ble Supreme Court (SC) in the case of Siemens [(2016) 390 ITR 1] held that subvention receipts from parent company to recoup losses is not taxable as revenue receipts since they are voluntary receipts and are made to protect capital investment. After introduction of section 56(2)(x) No consideration being discharged by subsidiary to the parent Gift taxation needs to be seen from the perspective of recipient Since there is absence of consideration, section 56(2)(x) shall apply November 10, 2018  :

Receipt of subsidy Regarded as income as per section 2(24)(xviii) Subsidies related to depreciable assets are considered for tax purposes and generally require reduction of cost base and accordingly precluded from section 56(2)(x) Grants received during the course of business will be subject to tax as PGBP and therefore the applicability of the IFOS chapter shall stand precluded. November 10, 2018  :

Personal obligation of one person met by another person Likely to be regarded at par with receipt of sum of money by a person whose obligation is relieved. Where the same is covered by provisions like section 2(24)(iv), section 2(22)(e) and 17(2)(iv), the same may not be taxable under the head IFOS, since they are specifically covered under other sections. November 10, 2018  :

Loan At the time of receipt- Not covered by section 56(2)(x) since there is a corresponding obligation to repay the loan. On waiver of loan- Madras High Court in the case of Ramaniyam Homes [(2016) 384 ITR 530] held that waiver of principal amount of loan for capital purpose is subject to tax under section 28(iv) and hence, no taxation under residual head November 10, 2018  :

Waiver of working capital loan specifically taxable under PGBP and hence, no taxation under residual head Where loan is based on bona fides and such loan is waived off or settled at a lower amount, it is arguable that the amount waived off cannot be regarded as constructive receipt by the borrower to trigger implications under section 56(2)(x). November 10, 2018  :

Security deposit money forfeited Taxable as trading receipt and hence, not covered by section 56(2)(x) November 10, 2018  :

Share application money forfeited Considered as a capital receipt and hence, not covered by section 56(2)(x) November 10, 2018  :

Receipt of consideration for breach committed by other parties to the contract Not taxable under section 56(2)(x) on account of the following: Payer of indemnity does not make payment out of love or affection The recipient of indemnity amount is likely to have suffered damage in the form of loss of money, loss of property, reputational loss, etc which substantiates that receipt of money is not without consideration but it lieu of adequate consideration and hence, it is not benefit akin to a gift. November 10, 2018  :

Receipt of non-compete fee There is presence of consideration in the form of refraining from undertaking certain activities/ business or restraining/ abstaining to share details, etc. Accordingly, not taxable under section 56(2)(x) November 10, 2018  :

Fresh issue of shares  : manojtiwariassociates@gmail.com
Whether fresh issue of shares taxable u/s 56(2)(x)? ‘Allotment of shares’ does not involve transfer- SC ruling in Khoday Distilleries Ltd. vs CIT and Anr. [(2008) 307 ITR 312] Therefore, it can be said that fresh issue / allotment of shares is not covered by provisions of section 56(2)(x) In the context of shares, allotment takes place by way of appropriation out of previously unappropriated capital of a company, of a certain number of shares, to a person and till such allotment, the shares do not exist This position forms basis for many scenarios where the applicability is decided upon whether there is a ‘fresh allotment’ or ‘actual transfer’ of shares November 10, 2018  :

Buyback of shares by Indian company from its shareholders
Shares received upon buyback not registered in the name of the company prior to cancellation thereof (from Companies Act perspective) Provisions of section 56(2)(x) of the Act should be not applicable November 10, 2018  :

Buyback of shares at less than FMV
Shares received by the company pursuant to buyback for cancellation has no value and cannot be regarded as less than fair consideration - SC judgement in the case of CTO vs State Bank of India (Civil Appeal No of 2005) Shares are never “received” by company since they may as one option be deemed to be cancelled without company receiving them. Property is not in existence post the transfer. Section 56(2)(x) is therefore not applicable. November 10, 2018  :

Conversion of company into LLP
Issue A Co, a private limited company with assets being only ‘investment in shares of unlisted company’ Conversion of A Co into LLP Shares held by A Co in unlisted company is effectively transferred to LLP November 10, 2018  :

Conversion of company into LLP
From perspective of LLP– Unlikely to be any tax implications under 56(2)(x) even if all the assets/ substantial assets of company are specified property as such conversion being statutory vesting of assets from the company into LLP as per provisions of LLP Act where no two parties exist at a time, there is no receipt of property so as to trigger Section 56(2)(x) of the Act From the perspective of shareholders/ partners- On conversion, shareholders receive interest in LLP Interest in LLP could not be considered as a specified property under 56(2)(x) In any case, substituted asset is received by shareholder for fair consideration as it is at the cost of extinguishment of the existing shares which also contain value equivalent to that of interest in LLP. There is no incremental benefit or enrichment from the standpoint of shareholders. November 10, 2018  :

Proviso to Section 12A  : manojtiwariassociates@gmail.com
Provided that where registration has been granted to the trust or institution under section 12AA, then, the provisions of sections 11 and 12 shall apply in respect of any income derived from property held under trust of any assessment year preceding the aforesaid assessment year, for which assessment proceedings are pending before the Assessing Officer as on the date of such registration and the objects and activities of such trust or institution remain the same for such preceding assessment year: Provided further that no action under section 147 shall be taken by the Assessing Officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year: Provided also that provisions contained in the first and second proviso shall not apply in case of any trust or institution which was refused registration or the registration granted to it was cancelled at any time under section 12AA. November 10, 2018  :

Section 115BBE Amended on 15th December, 2016 vide The Taxation Laws(Second Amendment), 2016

W.e.f. Assessment Year 2017-18 Sub-section (1) of Section 115BBE is substituted
“(1) Where the total income of an assessee,— includes any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D and reflected in the Return of Income furnished under section 139; or (b) determined by the Assessing Officer includes any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D, if such income is not covered under clause (a), the income-tax payable shall be the aggregate of— (i) the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent.; and (ii) the amount of income-tax with which the assessee would have been chargeable had his total income been reduced by the amount of income referred to in clause (i).”. November 10, 2018  :

W.e.f. Assessment Year 2017-18 Sub-section (1) of Section 115BBE is substituted
“(2) Notwithstanding anything contained in this Act, no deduction in respect of any expenditure or allowance or set off of any loss shall be allowed to the eligible assessee under any provision of this Act in computing his income referred to in clause (a) of Sub-section (1).” November 10, 2018  :

Tax Effect on account of Amendment
Amendment is made in Chapter II, in section 2, in sub-section (9) of the finance Act, Prior to amendment, if the total Income exceeded the specified amount, only then surcharge was applicable. Now, surcharge of 25% will apply to the Income determined u/s 115 BBE, irrespective of the total Income. Therefore, the effective rate will be 60% tax + 25% surcharge on tax + 3% cess on total of tax & surcharge = 77.25% as against 30.90% (with cess). Prior to amendment, it was considered Assessing Officer’s prerogative to invoke the provisions of Section 68, 69A, 69B, 69C & 69D if the Assessee is unable to explain the nature and source of it. November 10, 2018  :

Tax Effect on account of Amendment
After amendment, from Assessment Year , assesse is permitted to disclose his unexplained income on his own in Return of Income. Treatment of cash deposited due to demonetisation. If the source of income represented by deposit of specified bank notes can be explained then such income is not taxable u/s 115 BBE and will be taxed at normal rates as applicable to the Assessee. If not explainable, but offered in the Return of Income, 77.25% u/s.115BBE. If not explainable and not offered in the Return of Income, 77.25% plus 10% u/s 271AAC, totaling to 83.25%. November 10, 2018  :

Section 271AAC  : manojtiwariassociates@gmail.com
Introduced w.e.f. 01/04/2017, i.e. Assessment Year “271AAC. (1) The Assessing Officer may, notwithstanding anything contained in this Act other than the provisions of section 271AAB, direct that, in a case where the income determined includes any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D for any previous year, the assessee shall pay by way of penalty, in addition to tax payable under section 115BBE, a sum computed at the rate of ten per cent. of the tax payable under clause (i) of sub-section (1) of section 115BBE.” November 10, 2018  :

Rate of Penalty of Undisclosed Income
Section 271AAB Sl. No. Types of case Rate of Penalty of Undisclosed Income Old New 1. Assessee admits in statement u/s 132(4), specifies the manner and substantiates the manner in which the undisclosed income was derived. And pays taxes (incl. interest) and furnishes the Return of Income 10% 30% 2. Assessee does not admit in statement u/s 132(4) but declares in the Return of Income and pays tax (incl. Interest) 20% 60% 3. Not covered by the above 30% to 90% November 10, 2018  :

Consequences of section 115BBE
No basic exemption allowed while calculating tax at special rate under section 115BBE – No basic exemption is provided for while calculating the tax liability under the provisions of section 115BBE. In the Memorandum explaining the Finance Bill, 2012, the Legislature had made it clear that it desired to curb the practice of laundering of unaccounted money by taking advantage of the basic exemption limit. Here, one may refer to the proviso to clause (a) of sub-section (1) of section 112 of the Act whereby in case of long-term capital gain which is also taxed at a special rate, the benefit of basic exemption is granted. Section 115BBE does not contain any similar proviso. So, it is clear that no basic exemption is allowed while calculating tax at special rate under section 115BBE. November 10, 2018  :

Consequences of section 115BBE
Restriction on deductions under Chapter VI-A – Sub-section (2) of section 115BBE restricts deduction in respect of any expenditure allowable to the assessee under any provision of the Act. This is not to be confused with deductions admissible in computing "Gross Total Income" under Chapter VI-A. In the case of an assessee having income referred to in section 115BBE and no other income, while determining the "Gross total income", deduction under Chapter VI-A appears to be admissible. This will result into a lower 'Gross Total Income/Total income' as compared to income determined u/s 115BBE. November 10, 2018  :

Impact of section 115BBE under various circumstances
Bogus income claimed as exempt income from horse racing Claiming bogus income from horse racing as exempt - In the case of B.C. Paul v. CIT [1981] 6 Taxman 170 (Cal.), in return filed for the assessment year , the assessee, being not a regular punter, disclosed receipts of Rs. 1,58,250 but claimed the same to be exempt from tax on the ground that they were casual receipts from horse racing. ITO treated impugned amount as an income from undisclosed sources holding that there were discrepancies in assessee's statement and that assessee had failed to discharge onus of proving nature and source of impugned receipt. As the assessee failed to prove the receipts from horse racing as a genuine claim, the application of section 68 by the Assessing Officer was upheld. November 10, 2018  :

Impact of section 115BBE under various circumstances
Claiming amount as income from agricultural operations Claiming bogus income from agricultural operations as exempt - In the case of Avdhesh Kumar Jain v. CIT [1990] 48 Taxman 266 (All.), the assessee claimed that certain amount earned from agriculture operations was exempt. The ITO found that the assessee had failed to produce any satisfactory evidence about his being engaged in agricultural activities. The assessee was also not able to state as to whom the agricultural produce was sold. He, therefore, assessed the aforesaid amount as income from undisclosed sources in the hands of the assessee. November 10, 2018  :

Impact of section 115BBE when assessee credits “cash sales”
Legal precedents which directly deal with the issue ITO v. Jethu Ram Prem Chand [2001] 114 Taxman 219 (Delhi)(Mag.) Harish Kumar v. Dy. CIT [2003] 85 ITD 366 (Hyd.) Nitisha Silk Mills ( P.) Ltd. v. ITO [ IT Appeal No ( Ahd.) of 2011, dated ] November 10, 2018  :

Impact of section 115BBE when assessee credits “cash sales”
In all the cases cited above, although the attempt of the Revenue to tax cash sales as unaccounted income failed, yet it could not be said and concluded that cash sales were outside the purview of the provisions of section 68. The cases were decided in favour of the assesses on the basis of the facts and circumstances of the cases. In practical situations, it would be very difficult for assessees to keep fool-proof and detailed record of its transactions relating to purchases and sales. Petty traders running stalls on waysides, hawkers, etc. do not issue cash memos/bills and obtain purchase invoices. Wholesale Departmental stores like "Big Bazaar" making numerous transactions of sales in a day cannot carry out the exercise of "KYC", i.e, "know your customer" like banks. Although in cases of cash sales, an assessee is not required to prove the "source of source", yet then it would be a Herculean task for him to prove the nature and source of "cash sales". November 10, 2018  :

Rules notified for valuation of unquoted equity share for the purposes of Section 56 and Section 50CA of the Income-tax Act, 1961

New Rule 11UAA  : manojtiwariassociates@gmail.com
It provides that FMV of unquoted shares for purpose of Sec. 50CA shall be determined in manner provided in sub-clause (b) of clause (c), as the case may be, of Rule 11UA(1)(c) of the Rules. Valuation of unquoted shares should be undertaken on the date on which the capital asset, being unquoted share of a company, is transferred. Rule 11UAA is effective from onwards (i.e. AY onwards). November 10, 2018  :

New Rule 11UAA  : manojtiwariassociates@gmail.com
Valuation of Jewellery (i) The fair market value of jewellery shall be estimated to be the price which such jewellery would fetch if sold in the open market on the valuation date; (ii) In case the jewellery is received by the way of purchase on the valuation date, from a registered dealer, the invoice value of the jewellery shall be the fair market value; (iii) In case the jewellery is received by any other mode and the value of the jewellery exceeds rupees fifty thousand, then assessee may obtain the report of registered valuer in respect of the price it would fetch if sold in the open market on the valuation date; November 10, 2018  :

Rule 11UA(1) Clause (c) sub-clause (b)
The fair market value of unquoted equity shares shall be the value, on the valuation date, of such unquoted equity shares as determined in the following manner. November 10, 2018  :

Rule 11UA(1) Clause (c) sub-clause (c)
The fair market value of unquoted shares and securities other than equity shares in a company which are not listed in any recognized stock exchange shall be estimated to be price it would fetch if sold in the open market on the valuation date and the assessee may obtain a report from a merchant banker or an accountant in respect of such valuation. November 10, 2018  :

Our Comment  : manojtiwariassociates@gmail.com
Value of unquoted equity shares are mainly derived from intangibles assets such as goodwill, trademark or other intangible assets. Fails to give weightage to the fact as to whether shares being subject matter of transfer are of minority interest or majority interest. Prescribed method of valuation is specific for section 50CA and section 56(2)(x). In case of non-resident, three could be chances of conflict between normal provisions i.e. section 50CA and section 56(2) (x) and the provisions of transfer pricing. There could be difficulty at the time of withholding tax. November 10, 2018  :

Our Comment  : manojtiwariassociates@gmail.com
The valuation guideline is applicable from assessment year (i.e. financial year ). As the rules have been notified by the CBDT only on 12th July 2017, it seems to be retrospective in respect of transactions which have already taken place in the intermittent period i.e. between 1 April 2017 to 11 July 2017. November 10, 2018  :

CA. Manoj K Tiwari Manoj Tiwari & Associates P-221/1, Strand Bank Road, Kolkata –    : thank you

Prohibition of Benami Property Transactions Act, 1988

 : manojtiwariassociates@gmail.com
Benami is a Persian language word that means “without name” or “no name”. In this Act, the word is used to define a transaction in which the real beneficiary is not the one in whose name the property is purchased. As a result, the person in whose name the property is purchased is just a mask of the real beneficiary. November 10, 2018  :

Section 2 – clause (8)  : manojtiwariassociates@gmail.com
“Benami property" means any property which is the subject matter of a benami transaction and also includes the proceeds from such property; November 10, 2018  :

“Benami transaction" means,— (A) a transaction or an arrangement— (a) where a property is transferred to, or is held by, a person, and the consideration for such property has been provided, or paid by, another person; and (b) the property is held for the immediate or future benefit, direct or indirect, of the person who has provided the consideration, November 10, 2018  :

Except when the property is held by— (i) a Karta, or a member of a Hindu undivided family, as the case may be, and the property is held for his benefit or benefit of other members in the family and the consideration for such property has been provided or paid out of the known sources of the Hindu undivided family; November 10, 2018  :

(ii) a person standing in a fiduciary capacity for the benefit of another person towards whom mn he stands in such capacity and includes a trustee, executor, partner, director of a company, a depository or a participant as an agent of a depository under the Depositories Act, 1996 and any other person as may be notified by the Central Government for this purpose; November 10, 2018  :

(iii) any person being an individual in the name of his spouse or in the name of any child of such individual and the consideration for such property has been provided or paid out of the known sources of the individual; Earlier it was only for spouse or unmarried daughter. Now all children are covered under exception. November 10, 2018  :

(iv) any person in the name of his brother or sister or lineal ascendant or descendant, where the names of brother or sister or lineal ascendant or descendant and the individual appear as joint-owners in any document, and the consideration for such property has been provided or paid out of the known sources of the individual; or Earlier this category was not in the exception but now duly provided for. November 10, 2018  :

(B) a transaction or an arrangement in respect of a property carried out or made in a fictitious name; or (C) a transaction or an arrangement in respect of a property where the owner of the property is not aware of, or, denies knowledge of, such ownership; (D) a transaction or an arrangement in respect of a property where the person providing the consideration is not traceable or is fictitious; November 10, 2018  :

“Property" means assets of any kind, whether movable or immovable, tangible or intangible, corporeal or incorporeal and includes any right or interest or legal documents or instruments evidencing title to or interest in the property and where the property is capable of conversion into some other form, then the property in the converted form and also includes the proceeds from the property; November 10, 2018  :

Section 3 sub-section (1)
No Person shall enter into any benami transaction on and after the date of commencement of the Prohibition of Benami Property Transactions Act, 1988, shall, notwithstanding anything contained in sub-section (2), be punishable in accordance with the provisions contained in Chapter VII. November 10, 2018  :

Prohibition of the right to recover property held benami No suit, claim or action to enforce any right in respect of any property held benami against the person in whose name the property is held or against any other person shall lie by or on behalf of a person claiming to be the real owner of such property. November 10, 2018  :

Section 5  : manojtiwariassociates@gmail.com
Property held benami liable to confiscation Any property, which is subject matter of benami transaction, shall be liable to be confiscated by the Central Government. November 10, 2018  :

Prohibition on re-transfer of property by benamidar No person, being a benamidar shall re-transfer the benami property held by him to the beneficial owner or any other person acting on his behalf. November 10, 2018  :

(i) Initiating Officer, (ii) Approving Authority, (iii) Administrator and (iv) Adjudicating Authority. November 10, 2018  :

Notice and attachment of property involved in benami transaction – Where the Initiating Officer, on the basis of material in his possession, has reason to believe that any person is a benamidar in respect of a property, he may, after recording reasons in writing, issue a notice to the person to show cause within such time as may be specified in the notice why the property should not be treated as benami property. November 10, 2018  :

Where the Initiating Officer is of the opinion that the person in possession of the property held benami may alienate the property during the period specified in the notice, he may, with the previous approval of the Approving Authority, by order in writing, attach provisionally the property in the manner as may be prescribed, for a period not exceeding ninety days from the date of issue of notice under sub-section (1). November 10, 2018  :

Adjudication of benami property - On receipt of a reference under sub-section (5) of section 24, the Adjudicating Authority shall issue notice, to furnish such documents, particulars or evidence as is considered necessary on a date to be specified therein, on the following persons, namely:— November 10, 2018  :

(a) the person specified as a benamidar therein; (b) any person referred to as the beneficial owner therein or identified as such; (c) any interested party, including a banking company; (d) any person who has made a claim in respect of the property. November 10, 2018  :

No order under sub-section (3) shall be passed after the expiry of one year from the end of the month in which the reference under sub-section (5) of section 24 was received. November 10, 2018  :

Confiscation and vesting of benami property – Where an order is passed in respect of any property under sub-section (3) of section 26 holding such property to be a benami property, the Adjudicating Authority shall, after giving an opportunity of being heard to the person concerned, make an order confiscating the property held to be a benami property. November 10, 2018  :

Management of property confiscated by the administrator
Section 28 Management of property confiscated by the administrator November 10, 2018  :

Possession of the property confiscated
Section 29 Possession of the property confiscated November 10, 2018  :

Where any person enters into a benami transaction in order to defeat the provisions of any law or to avoid payment of statutory dues or to avoid payment to creditors, the beneficial owner, benamidar and any other person who abets or induces any person to enter into the benami transaction, shall be guilty of the offence of benami transaction. November 10, 2018  :

Whoever is found guilty of the offence of benami transaction referred to in sub-section (1) shall be punishable with rigorous imprisonment for a term which shall not be less than one year, but which may extend to seven years and shall also be liable to fine which may extend to twenty-five percent of the fair market value of the property. November 10, 2018  :

Section 54  : manojtiwariassociates@gmail.com
Any person who is required to furnish information under this Act knowingly gives false information to any authority or furnishes any false document in any proceeding under this Act, shall be punishable with rigorous imprisonment for a term which shall not be less than six months but which may extend to five years and shall also be liable to fine which may extend to ten per cent. of the fair market value of the property . November 10, 2018  :

CA Manoj K Tiwari welcomes you.

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