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...
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HC affirmed ED's authority to conduct search, seizure, and account freezing operations under FEMA 1999 and PMLA 2002. Court held that interference during investigation stage is warranted only in exceptional circumstances, as law enforcement requires both coercive and covert techniques. ED demonstrated reasonable belief of proceeds of crime, provided proper documentation during search, and followed procedural requirements. Statutory safeguards exist through Adjudicating Authority review within 30 days of attachment order, with stakeholder participation rights and appeal provisions to Appellate Tribunal. Court declined to intervene, directing petitioners to pursue remedies through established administrative mechanisms under the Acts.
HC affirmed ED's authority to conduct search, seizure, and account freezing operations under FEMA 1999 and PMLA 2002. Court held that interference during investigation stage is warranted only in exceptional circumstances, as law enforcement requires both coercive and covert techniques. ED demonstrated reasonable belief of proceeds of crime, provided proper documentation during search, and followed procedural requirements. Statutory safeguards exist through Adjudicating Authority review within 30 days of attachment order, with stakeholder participation rights and appeal provisions to Appellate Tribunal. Court declined to intervene, directing petitioners to pursue remedies through established administrative mechanisms under the Acts.
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