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...
The AT dismissed the appeal and upheld the impugned order, sustaining provisional attachment and investigation findings under the PMLA. The Tribunal found overwhelming documentary evidence of illicit fund flows from a statutory authority to an intermediary merchant and thereafter to the appellant firm, including identified cheque transfers of substantial sums. The AT rejected allegations that statements were recorded under coercion as unsubstantiated and belated. The Tribunal also affirmed the Directorate's statutory mandate to investigate under the PMLA and treated the ECIR-linked proceedings as lawful. Despite procedural defects alleged in Coram composition and notice opportunity, the AT declined to interfere with the substantive findings and confirmed the attachment and continuation of proceedings.
The AT dismissed the appeal and upheld the impugned order, sustaining provisional attachment and investigation findings under the PMLA. The Tribunal found overwhelming documentary evidence of illicit fund flows from a statutory authority to an intermediary merchant and thereafter to the appellant firm, including identified cheque transfers of substantial sums. The AT rejected allegations that statements were recorded under coercion as unsubstantiated and belated. The Tribunal also affirmed the Directorate's statutory mandate to investigate under the PMLA and treated the ECIR-linked proceedings as lawful. Despite procedural defects alleged in Coram composition and notice opportunity, the AT declined to interfere with the substantive findings and confirmed the attachment and continuation of proceedings.
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