Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
A prima facie money trail traced through forensic audit and fund movements showed diversion of company funds through fictitious procurement transactions and routing to vendors before transfer to the appellants, their family members and related entities. The Tribunal held that this material, together with the statutory burden on the appellants, required proof of a lawful source; mere assertions of consultancy charges, salary or rental income were insufficient without supporting evidence. The retention and freezing of the bank accounts, mutual funds, DEMAT accounts and other movable properties were therefore upheld as proceeds of crime, subject to the final outcome of the trial.
A prima facie money trail traced through forensic audit and fund movements showed diversion of company funds through fictitious procurement transactions and routing to vendors before transfer to the appellants, their family members and related entities. The Tribunal held that this material, together with the statutory burden on the appellants, required proof of a lawful source; mere assertions of consultancy charges, salary or rental income were insufficient without supporting evidence. The retention and freezing of the bank accounts, mutual funds, DEMAT accounts and other movable properties were therefore upheld as proceeds of crime, subject to the final outcome of the trial.
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