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...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
The Tribunal discussed PMLA attachment where the money trail showed circulation of funds through group companies, paper entities and restructuring arrangements, and held that such routing could constitute layering and proceeds of crime. It rejected explanations based on surplus funds, security deposits, home loans or corporate debt restructuring when unsupported by records, and noted that the burden to disprove taint lay on the claimant. It also accepted equivalent value attachment where diverted funds were no longer available and sustained provisional attachment of properties, subject to the final outcome of trial.
The Tribunal discussed PMLA attachment where the money trail showed circulation of funds through group companies, paper entities and restructuring arrangements, and held that such routing could constitute layering and proceeds of crime. It rejected explanations based on surplus funds, security deposits, home loans or corporate debt restructuring when unsupported by records, and noted that the burden to disprove taint lay on the claimant. It also accepted equivalent value attachment where diverted funds were no longer available and sustained provisional attachment of properties, subject to the final outcome of trial.
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