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...
The Appellate Tribunal addressed two key issues: 1) The duration for which property can be retained u/s 20(3) of PMLA, 2002, and 2) The constitution of the Adjudicating Authority. The Tribunal found that the Adjudicating Authority exceeded the 180-day limit for retaining seized property due to Covid-19 related extensions. Citing precedents, the Tribunal ruled that the excluded period from 15.03.2020 to 28.02.2022 should not count towards the 180-day limit. Additionally, it upheld the competence of a single-member bench as the Adjudicating Authority based on judgments from Calcutta High Court and Telangana High Court. The appeal was dismissed for lacking merit.
The Appellate Tribunal addressed two key issues: 1) The duration for which property can be retained u/s 20(3) of PMLA, 2002, and 2) The constitution of the Adjudicating Authority. The Tribunal found that the Adjudicating Authority exceeded the 180-day limit for retaining seized property due to Covid-19 related extensions. Citing precedents, the Tribunal ruled that the excluded period from 15.03.2020 to 28.02.2022 should not count towards the 180-day limit. Additionally, it upheld the competence of a single-member bench as the Adjudicating Authority based on judgments from Calcutta High Court and Telangana High Court. The appeal was dismissed for lacking merit.
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