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...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
ECIR is an internal, non-statutory departmental record that neither initiates prosecution nor independently imposes penal consequences. A first-instance acquittal in a scheduled offence is not final absolution while subject to appeal and does not determine the legitimacy of separately seized assets. The PMLA's specialised adjudicatory and appellate mechanism governs property retention and confiscation; writ jurisdiction should not bypass it where disputed financial facts require evidentiary assessment. Material indicating contravention of another law must be shared with the relevant agency under section 66(2), independently of an acquittal in a distinct predicate proceeding. The writ petition was dismissed, leaving statutory remedies available.
ECIR is an internal, non-statutory departmental record that neither initiates prosecution nor independently imposes penal consequences. A first-instance acquittal in a scheduled offence is not final absolution while subject to appeal and does not determine the legitimacy of separately seized assets. The PMLA's specialised adjudicatory and appellate mechanism governs property retention and confiscation; writ jurisdiction should not bypass it where disputed financial facts require evidentiary assessment. Material indicating contravention of another law must be shared with the relevant agency under section 66(2), independently of an acquittal in a distinct predicate proceeding. The writ petition was dismissed, leaving statutory remedies available.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
