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 appeals, upholding the ED's provisional attachment orders under PMLA. It held that ED's investigation is confined to the quantum of proceeds of crime and related procedural aspects, without re-examining the predicate offence findings of police/CBI. The retrospective application of PMLA was deemed valid, as attachment procedures existed pre-PMLA under CrPC and other statutes. The ED had sufficient reason to believe appellants possessed proceeds of crime, given evidence of financial fraud and misutilisation of loan funds. Properties of equivalent value were rightly attached despite no direct link to proceeds of crime, applying the extended definition under PMLA. Sham transactions to evade attachment were rejected, with claimants directed to seek relief in trial court. Claims of jewellery as stridhan lacked documentary proof and were reserved for trial court determination. The appeals were dismissed for lack of merit, affirming ED's attachment actions.
The AT dismissed the appeals, upholding the ED's provisional attachment orders under PMLA. It held that ED's investigation is confined to the quantum of proceeds of crime and related procedural aspects, without re-examining the predicate offence findings of police/CBI. The retrospective application of PMLA was deemed valid, as attachment procedures existed pre-PMLA under CrPC and other statutes. The ED had sufficient reason to believe appellants possessed proceeds of crime, given evidence of financial fraud and misutilisation of loan funds. Properties of equivalent value were rightly attached despite no direct link to proceeds of crime, applying the extended definition under PMLA. Sham transactions to evade attachment were rejected, with claimants directed to seek relief in trial court. Claims of jewellery as stridhan lacked documentary proof and were reserved for trial court determination. The appeals were dismissed for lack of merit, affirming ED's attachment actions.
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