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 the appellant company, finding substantial evidence of money laundering activities. The tribunal determined that the company was involved in layering funds for PFI through suspicious financial transactions, with unexplained discrepancies of Rs. 90 lakhs in cash books. The court found reasonable apprehension of property concealment under Section 5(1) of PMLA, 2002, and concluded that the attached immovable properties were proceeds of crime connected to scheduled offences. The appellant failed to justify the source of funds or challenge the allegations effectively. Consequently, the appeal challenging the provisional attachment was dismissed, confirming the original order's legal validity.
The AT upheld the provisional attachment order against the appellant company, finding substantial evidence of money laundering activities. The tribunal determined that the company was involved in layering funds for PFI through suspicious financial transactions, with unexplained discrepancies of Rs. 90 lakhs in cash books. The court found reasonable apprehension of property concealment under Section 5(1) of PMLA, 2002, and concluded that the attached immovable properties were proceeds of crime connected to scheduled offences. The appellant failed to justify the source of funds or challenge the allegations effectively. Consequently, the appeal challenging the provisional attachment was dismissed, confirming the original order's legal validity.
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TaxTMI 
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