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 HC allowed the appeal, set aside the impugned SJ judgment and reinstated the Provisional Attachment Order (PAO) and consequential proceedings. The court held the writ challenge under Art.226 was not maintainable as Whirlpool parameters were not attracted; no breach of natural justice occurred and the PAO is provisional pending adjudication. The HC confirmed a sufficient nexus between the scheduled predicate offence (fraud/misrepresentation) and the attached proceeds, endorsing the Directorate's tracing of enhanced value as proceeds of crime under s.3 PMLA. Compliance with s.66(2) PMLA was held not to be a condition precedent to issuance of a s.5 PAO.
The HC allowed the appeal, set aside the impugned SJ judgment and reinstated the Provisional Attachment Order (PAO) and consequential proceedings. The court held the writ challenge under Art.226 was not maintainable as Whirlpool parameters were not attracted; no breach of natural justice occurred and the PAO is provisional pending adjudication. The HC confirmed a sufficient nexus between the scheduled predicate offence (fraud/misrepresentation) and the attached proceeds, endorsing the Directorate's tracing of enhanced value as proceeds of crime under s.3 PMLA. Compliance with s.66(2) PMLA was held not to be a condition precedent to issuance of a s.5 PAO.
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