Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's...
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional b...
Special insurance income computation preserves statutory deductions while limiting transfer-pricing, withholding and disallowance adjustments for gene...
Under the PMLA, property equivalent in value to unavailable proceeds of crime may be attached without a direct nexus to the offence where receipt and expenditure of tainted cash are admitted; statements recorded under Section 50 may support that conclusion if unretracted and corroborated. Holders, including non-accused persons, bear the burden of proving a legitimate source of acquisition; income-tax returns or unsupported claims do not discharge it, although capital-account withdrawals must be considered. Provisional attachment also requires a reasoned apprehension of concealment, transfer or dealing that could frustrate confiscation; property already in investigative custody or subject to a bank mortgage may not satisfy that condition. Recorded reasons and consideration of objections support a valid attachment process.
Under the PMLA, property equivalent in value to unavailable proceeds of crime may be attached without a direct nexus to the offence where receipt and expenditure of tainted cash are admitted; statements recorded under Section 50 may support that conclusion if unretracted and corroborated. Holders, including non-accused persons, bear the burden of proving a legitimate source of acquisition; income-tax returns or unsupported claims do not discharge it, although capital-account withdrawals must be considered. Provisional attachment also requires a reasoned apprehension of concealment, transfer or dealing that could frustrate confiscation; property already in investigative custody or subject to a bank mortgage may not satisfy that condition. Recorded reasons and consideration of objections support a valid attachment process.
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