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...
AT determined appellant's property was proceeds of crime under PMLA, arising from NSEL fraud scheme. Evidence established appellant's spouse was a senior NSEL executive involved in systematic financial manipulation, with property purchased using fraudulently obtained consultancy charges. Despite appellant's claims of legitimate income, the tribunal found her defense unsubstantiated and concluded the property was directly linked to criminal proceeds. The tribunal rejected appellant's arguments regarding property valuation and lack of predicate offense chargesheet, confirming full property attachment. Appeal was consequently dismissed, upholding the original attachment order.
AT determined appellant's property was proceeds of crime under PMLA, arising from NSEL fraud scheme. Evidence established appellant's spouse was a senior NSEL executive involved in systematic financial manipulation, with property purchased using fraudulently obtained consultancy charges. Despite appellant's claims of legitimate income, the tribunal found her defense unsubstantiated and concluded the property was directly linked to criminal proceeds. The tribunal rejected appellant's arguments regarding property valuation and lack of predicate offense chargesheet, confirming full property attachment. Appeal was consequently dismissed, upholding the original attachment order.
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