Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
The High Court examined whether it is appropriate to entertain a writ petition against a Provisional Attachment Order (PAO) issued under the Prevention of Money Laundering Act, 2002, before the statutory period of 30 days when the Adjudicating Authority is required to examine it. The Supreme Court has upheld the validity of Section 5 of the Act, finding adequate safeguards to give an opportunity to the aggrieved person to file objections before the Adjudicating Authority. The PAO is passed by the Director or authorized officer with reasons based on material in possession. Since sufficient remedies are available under the Act, the High Court held it inappropriate to entertain the petition before the 30-day period expires, except in rare and exceptional cases. The petitioner was relegated to avail alternative remedies, and the Adjudicating Authority was directed to expedite the matter without observations on merits.
The High Court examined whether it is appropriate to entertain a writ petition against a Provisional Attachment Order (PAO) issued under the Prevention of Money Laundering Act, 2002, before the statutory period of 30 days when the Adjudicating Authority is required to examine it. The Supreme Court has upheld the validity of Section 5 of the Act, finding adequate safeguards to give an opportunity to the aggrieved person to file objections before the Adjudicating Authority. The PAO is passed by the Director or authorized officer with reasons based on material in possession. Since sufficient remedies are available under the Act, the High Court held it inappropriate to entertain the petition before the 30-day period expires, except in rare and exceptional cases. The petitioner was relegated to avail alternative remedies, and the Adjudicating Authority was directed to expedite the matter without observations on merits.
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