Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Money-laundering under the PMLA was treated as a continuing activity; the relevant date is when a person engages in or continues dealing with proceeds of crime, not merely the date of the predicate offence. On the facts, the appellant continued to derive benefit from unauthorized construction and related transactions, the ECIR was recorded when the scheduled-offence requirement stood attracted, and the ECIR had not been quashed. The Article 20(1) challenge and the plea based on absence of scheduled-offence status at the initial point of time were rejected, and confirmation of provisional attachment was upheld, with the appeal dismissed.
Money-laundering under the PMLA was treated as a continuing activity; the relevant date is when a person engages in or continues dealing with proceeds of crime, not merely the date of the predicate offence. On the facts, the appellant continued to derive benefit from unauthorized construction and related transactions, the ECIR was recorded when the scheduled-offence requirement stood attracted, and the ECIR had not been quashed. The Article 20(1) challenge and the plea based on absence of scheduled-offence status at the initial point of time were rejected, and confirmation of provisional attachment was upheld, with the appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
