Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
AT held that the provisional attachment order (PAO) under Section 5(1) of the PMLA was validly issued. The Deputy Director possessed and recorded in writing adequate reasons to believe, grounded in seized cash, FIRs, fund transfers, witness statements and account transaction records demonstrating transfers from entities controlled by the appellants and a prima facie contravention of statutory norms. The Tribunal found the satisfaction to be a subjective yet material-based belief of a reasonable officer, not mere ipsi dixit, and that the statutory procedure did not mandate pre-decision communication of the recorded reasons to the appellants. Given the availability of a post-attachment hearing before the Adjudicating Authority, the application was disposed of.
AT held that the provisional attachment order (PAO) under Section 5(1) of the PMLA was validly issued. The Deputy Director possessed and recorded in writing adequate reasons to believe, grounded in seized cash, FIRs, fund transfers, witness statements and account transaction records demonstrating transfers from entities controlled by the appellants and a prima facie contravention of statutory norms. The Tribunal found the satisfaction to be a subjective yet material-based belief of a reasonable officer, not mere ipsi dixit, and that the statutory procedure did not mandate pre-decision communication of the recorded reasons to the appellants. Given the availability of a post-attachment hearing before the Adjudicating Authority, the application was disposed of.
Note: It is a system-generated summary and is for quick reference only.