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 upheld the impugned order and dismissed the petition filed by A1 challenging the expansion of investigation under PMLA. The HC held that the offence of money laundering is a standalone offence, distinct from the predicate offence, and that investigation, complaint (charge sheet) and trial under PMLA are independent proceedings not contingent upon the status or outcome of the predicate offence case. The Court rejected the contention that the Enforcement Directorate is bound by the temporal or factual limits of the predicate offence investigation, emphasizing that any restriction on money-laundering investigation would defeat the object of PMLA. The HC further observed that an accused in a predicate offence need not be an accused in a PMLA case and vice versa.
The HC upheld the impugned order and dismissed the petition filed by A1 challenging the expansion of investigation under PMLA. The HC held that the offence of money laundering is a standalone offence, distinct from the predicate offence, and that investigation, complaint (charge sheet) and trial under PMLA are independent proceedings not contingent upon the status or outcome of the predicate offence case. The Court rejected the contention that the Enforcement Directorate is bound by the temporal or factual limits of the predicate offence investigation, emphasizing that any restriction on money-laundering investigation would defeat the object of PMLA. The HC further observed that an accused in a predicate offence need not be an accused in a PMLA case and vice versa.
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