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 dismissed the appeal challenging the provisional attachment order under the PMLA, holding that the appellants failed to satisfactorily disclose the sources of funds credited to their bank accounts. Evidence demonstrated that substantial amounts received by the appellants and related entities were proceeds of crime linked to fraudulent export activities. The appellants could not substantiate the legitimacy of the funds, nor provide credible documentation such as loan agreements or valid explanations for the transfers. The tribunal noted the close familial and transactional connections between the appellants and accused persons involved in money laundering. Given the lack of credible disclosure and the established nexus to criminal proceeds, the impugned attachment order was upheld, with no grounds for interference in favor of the appellants.
The AT dismissed the appeal challenging the provisional attachment order under the PMLA, holding that the appellants failed to satisfactorily disclose the sources of funds credited to their bank accounts. Evidence demonstrated that substantial amounts received by the appellants and related entities were proceeds of crime linked to fraudulent export activities. The appellants could not substantiate the legitimacy of the funds, nor provide credible documentation such as loan agreements or valid explanations for the transfers. The tribunal noted the close familial and transactional connections between the appellants and accused persons involved in money laundering. Given the lack of credible disclosure and the established nexus to criminal proceeds, the impugned attachment order was upheld, with no grounds for interference in favor of the appellants.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
