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...
AT held that the provisional attachment of the immovable property in question was lawful and constituted a valid measure to preserve proceeds of crime. The tribunal found that Company X, in collusion with Bank Y and Individuals A and B, mortgaged third-party properties and submitted fabricated documents to obtain a Rs.15 crore factoring facility; funds were diverted for personal use, resulting in illegal gratification of Rs.50 lakhs to the appellant and misappropriation of approximately Rs.9 crores. Given these findings of commission of criminality and diversion of proceeds, there was no infirmity in attaching the flat; accordingly the appeal challenging the provisional attachment was dismissed and the order upheld.
AT held that the provisional attachment of the immovable property in question was lawful and constituted a valid measure to preserve proceeds of crime. The tribunal found that Company X, in collusion with Bank Y and Individuals A and B, mortgaged third-party properties and submitted fabricated documents to obtain a Rs.15 crore factoring facility; funds were diverted for personal use, resulting in illegal gratification of Rs.50 lakhs to the appellant and misappropriation of approximately Rs.9 crores. Given these findings of commission of criminality and diversion of proceeds, there was no infirmity in attaching the flat; accordingly the appeal challenging the provisional attachment was dismissed and the order upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
