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...
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The AT upholds the finding of contravention of Section 9(1)(b) and 9(1)(d) of the Act of 1973 against the appellant, holding his confessional statement-recorded after issuance of summons and not during custody-admissible and made voluntarily; co-noticee statements and documentary material corroborated involvement in hawala-style transactions. The AT declines to follow the High Court's acquittal rationale, applying the Apex Court principle that a voluntary confession in civil proceedings requires no further corroboration. The AT reduces the imposed penalty from Rs. 20,00,000 to Rs. 5,00,000 in view of mitigating circumstances (including age and pre-deposit), affirms confiscation of Rs. 21,80,000, and disposes of the appeal accordingly.
The AT upholds the finding of contravention of Section 9(1)(b) and 9(1)(d) of the Act of 1973 against the appellant, holding his confessional statement-recorded after issuance of summons and not during custody-admissible and made voluntarily; co-noticee statements and documentary material corroborated involvement in hawala-style transactions. The AT declines to follow the High Court's acquittal rationale, applying the Apex Court principle that a voluntary confession in civil proceedings requires no further corroboration. The AT reduces the imposed penalty from Rs. 20,00,000 to Rs. 5,00,000 in view of mitigating circumstances (including age and pre-deposit), affirms confiscation of Rs. 21,80,000, and disposes of the appeal accordingly.
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