Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
AT dismissed the appeals and upheld retention of the appellant's frozen bank accounts pending trial. The Tribunal found sufficient prima facie evidence linking the appellant and associated corporate entities to an alleged Ponzi/MLM money-circulation scheme, including benami firm usage, routing of proceeds through related companies and personal accounts, recovery of incriminating material on search, and receipt of large "commissions." The appellant failed to discharge the statutory obligation under s.8(1) of the Act to explain the source of funds; statements under ss.50(2)-50(3) were treated as corroborative. On these findings, AT concluded continued attachment of funds was justified and dismissed the appeals for lack of merit.
AT dismissed the appeals and upheld retention of the appellant's frozen bank accounts pending trial. The Tribunal found sufficient prima facie evidence linking the appellant and associated corporate entities to an alleged Ponzi/MLM money-circulation scheme, including benami firm usage, routing of proceeds through related companies and personal accounts, recovery of incriminating material on search, and receipt of large "commissions." The appellant failed to discharge the statutory obligation under s.8(1) of the Act to explain the source of funds; statements under ss.50(2)-50(3) were treated as corroborative. On these findings, AT concluded continued attachment of funds was justified and dismissed the appeals for lack of merit.
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