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...
The Court held that the procedure followed by the Directorate of Enforcement in seizing and selling the luxury vehicles was in accordance with the provisions of the Prevention of Money Laundering Act (PMLA) and the Rules of 2013. The vehicles were prima facie found to have been purchased from the proceeds of crime generated through criminal activities. The Court recognized that vehicles are subject to natural decay and depreciation, making them economically unviable over time. By converting the sale proceeds into fixed deposits, the Rules ensure preservation and potential increase in value, protecting the rights of both the accused and the investigating agency. The petitioner did not request the retention of vehicles in exchange for fixed deposits. The sale does not violate Section 8(6) of PMLA, as the accused would receive the sale proceeds if acquitted. The Court found no infirmity in the impugned orders and dismissed the petition.
The Court held that the procedure followed by the Directorate of Enforcement in seizing and selling the luxury vehicles was in accordance with the provisions of the Prevention of Money Laundering Act (PMLA) and the Rules of 2013. The vehicles were prima facie found to have been purchased from the proceeds of crime generated through criminal activities. The Court recognized that vehicles are subject to natural decay and depreciation, making them economically unviable over time. By converting the sale proceeds into fixed deposits, the Rules ensure preservation and potential increase in value, protecting the rights of both the accused and the investigating agency. The petitioner did not request the retention of vehicles in exchange for fixed deposits. The sale does not violate Section 8(6) of PMLA, as the accused would receive the sale proceeds if acquitted. The Court found no infirmity in the impugned orders and dismissed the petition.
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TaxTMI 
TaxTMI 
of 4918 
