Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
PMLA adjudication permits a single-member Adjudicating Authority constituted by its Chairperson to include a non-judicial member, because attachment scrutiny does not transfer High Court functions and appellate review remains available. Provisional attachment requires recorded reasons to believe that non-attachment may frustrate proceedings; factual challenges to that satisfaction lie through the statutory appellate process. The Adjudicating Authority must independently record reasons to believe that a person possesses proceeds of crime before issuing notice. Properties acquired before the scheduled offence may also be attached in proceeds-of-crime proceedings. Challenges to the single-member order, attachment reasons, independent satisfaction and pre-offence property attachment were rejected in writ jurisdiction.
PMLA adjudication permits a single-member Adjudicating Authority constituted by its Chairperson to include a non-judicial member, because attachment scrutiny does not transfer High Court functions and appellate review remains available. Provisional attachment requires recorded reasons to believe that non-attachment may frustrate proceedings; factual challenges to that satisfaction lie through the statutory appellate process. The Adjudicating Authority must independently record reasons to believe that a person possesses proceeds of crime before issuing notice. Properties acquired before the scheduled offence may also be attached in proceeds-of-crime proceedings. Challenges to the single-member order, attachment reasons, independent satisfaction and pre-offence property attachment were rejected in writ jurisdiction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
