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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Money laundering - scheduled offences or not - proceeds of crime - offences under various sections of the Income-tax Act, 1961, in conjunction with sections of the Indian Penal Code, 1860 (IPC) - The Supreme Court reiterated that the existence of a scheduled offence is a prerequisite for establishing proceeds of crime under the PMLA. Since the offences alleged in the complaint did not qualify as scheduled offences, the Court ruled out the presence of proceeds of crime and consequently, the applicability of Section 3 of the PMLA.
Money laundering - scheduled offences or not - proceeds of crime - offences under various sections of the Income-tax Act, 1961, in conjunction with sections of the Indian Penal Code, 1860 (IPC) - The Supreme Court reiterated that the existence of a scheduled offence is a prerequisite for establishing proceeds of crime under the PMLA. Since the offences alleged in the complaint did not qualify as scheduled offences, the Court ruled out the presence of proceeds of crime and consequently, the applicability of Section 3 of the PMLA.
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