Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The AT dismissed the appeal challenging provisional attachment orders under PMLA. The appellants contended properties acquired prior to PMLA enforcement and scheduled offence commission could not be attached, arguing lack of connection with proceeds of crime and non-compliance with Section 5(1) conditions. The AT held that properties acquired as "value thereof" need not prove direct connection with proceeds of crime when direct proceeds are absent. Settlement deeds executed post-fraud discovery were deemed attempts to frustrate PMLA proceedings, justifying immediate attachment under the second proviso of Section 5(1). The appellant failed to establish legal income sources for property acquisition despite claiming transfer via settlement deed. The AT ruled ED need not conduct independent investigation of predicate offences, only identify glaring mistakes in police investigations while maintaining consistency with predicate offence conclusions.
The AT dismissed the appeal challenging provisional attachment orders under PMLA. The appellants contended properties acquired prior to PMLA enforcement and scheduled offence commission could not be attached, arguing lack of connection with proceeds of crime and non-compliance with Section 5(1) conditions. The AT held that properties acquired as "value thereof" need not prove direct connection with proceeds of crime when direct proceeds are absent. Settlement deeds executed post-fraud discovery were deemed attempts to frustrate PMLA proceedings, justifying immediate attachment under the second proviso of Section 5(1). The appellant failed to establish legal income sources for property acquisition despite claiming transfer via settlement deed. The AT ruled ED need not conduct independent investigation of predicate offences, only identify glaring mistakes in police investigations while maintaining consistency with predicate offence conclusions.
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