Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The AT held that enhanced compensation fraudulently received after the claimants' own enhancement proceedings had failed constituted proceeds of crime, and that later possession and projection of that money as untainted property fell within money-laundering under Section 3. It further held that where the tainted property is unavailable, equivalent value property may be attached under Section 2(1)(u), even if the attached asset is ancestral or was acquired earlier, so long as it represents equivalent value. The Tribunal also interpreted Section 5(1) to require only an apprehended likelihood of concealment or transfer, not proof of actual alienation, and upheld the provisional attachment orders.
The AT held that enhanced compensation fraudulently received after the claimants' own enhancement proceedings had failed constituted proceeds of crime, and that later possession and projection of that money as untainted property fell within money-laundering under Section 3. It further held that where the tainted property is unavailable, equivalent value property may be attached under Section 2(1)(u), even if the attached asset is ancestral or was acquired earlier, so long as it represents equivalent value. The Tribunal also interpreted Section 5(1) to require only an apprehended likelihood of concealment or transfer, not proof of actual alienation, and upheld the provisional attachment orders.
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