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...
AT dismissed appeals challenging provisional attachment orders in a money laundering case involving large-scale extortion in coal transportation. Appellants failed to prove legitimate sources for acquiring 52 properties through alleged layering of proceeds of crime. Claims of being bona fide purchasers were rejected due to inability to demonstrate valid cash sources. Court upheld that properties acquired before FIR registration could be attached as criminal activities predated FIR. Arguments regarding absence of predicate offense were dismissed, citing established Supreme Court precedents. The provisional attachment was confirmed as appellants were either accused or in possession of proceeds of crime, with sufficient reasons provided in show cause notices.
AT dismissed appeals challenging provisional attachment orders in a money laundering case involving large-scale extortion in coal transportation. Appellants failed to prove legitimate sources for acquiring 52 properties through alleged layering of proceeds of crime. Claims of being bona fide purchasers were rejected due to inability to demonstrate valid cash sources. Court upheld that properties acquired before FIR registration could be attached as criminal activities predated FIR. Arguments regarding absence of predicate offense were dismissed, citing established Supreme Court precedents. The provisional attachment was confirmed as appellants were either accused or in possession of proceeds of crime, with sufficient reasons provided in show cause notices.
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