Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The AT dismissed the appeal. The appellant company was found to be a sham entity established to launder proceeds of crime by an accused, Mr. Anurag Gupta. The ED complied with procedural requirements u/ss 5, 17 and 20 of PMLA for retaining seized properties prima facie involved in money laundering. The offence being independent, the appellant could be proceeded against despite not being named in the scheduled offence FIR/chargesheet, as it possessed unexplained proceeds of crime.
The AT dismissed the appeal. The appellant company was found to be a sham entity established to launder proceeds of crime by an accused, Mr. Anurag Gupta. The ED complied with procedural requirements u/ss 5, 17 and 20 of PMLA for retaining seized properties prima facie involved in money laundering. The offence being independent, the appellant could be proceeded against despite not being named in the scheduled offence FIR/chargesheet, as it possessed unexplained proceeds of crime.
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