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 AT upheld the Provisional Attachment Order against property owned by Heera Retail Pvt. Ltd., a group company of the main accused. The appellants' claim based on a civil court decree was rejected as Heera Retail was not party to the civil suit, rendering the decree non-binding on the company. The property had been purchased using proceeds of crime (diverted depositors' funds) prior to the decree. The Tribunal determined that the collusive decree obtained by appellants could not prevail against unchallenged sale deeds executed in favor of the accused's company. The attachment remains valid subject to the Supreme Court's directions regarding realization of investors' dues.
The AT upheld the Provisional Attachment Order against property owned by Heera Retail Pvt. Ltd., a group company of the main accused. The appellants' claim based on a civil court decree was rejected as Heera Retail was not party to the civil suit, rendering the decree non-binding on the company. The property had been purchased using proceeds of crime (diverted depositors' funds) prior to the decree. The Tribunal determined that the collusive decree obtained by appellants could not prevail against unchallenged sale deeds executed in favor of the accused's company. The attachment remains valid subject to the Supreme Court's directions regarding realization of investors' dues.
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