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...
Whether provisional attachment under the PMLA was validly exercised: Court held that attachment requires the property to be "proceeds of crime" and material to show relation to a scheduled offence; absent evidence of criminal activity or that the predicate offence (Section 13 PC) was a scheduled offence at the relevant time, attachment was misplaced - appeal dismissed on merits. Whether recorded concessions/admissions by counsel could be contradicted: factual recital in the impugned order is conclusive and, having not been corrected before the same forum, cannot be reopened in the appeal - therefore such challenge was rejected. Relief modified: refund of interest ordered but 50% of accrued interest directed to AFBCWF. - HC
Whether provisional attachment under the PMLA was validly exercised: Court held that attachment requires the property to be "proceeds of crime" and material to show relation to a scheduled offence; absent evidence of criminal activity or that the predicate offence (Section 13 PC) was a scheduled offence at the relevant time, attachment was misplaced - appeal dismissed on merits. Whether recorded concessions/admissions by counsel could be contradicted: factual recital in the impugned order is conclusive and, having not been corrected before the same forum, cannot be reopened in the appeal - therefore such challenge was rejected. Relief modified: refund of interest ordered but 50% of accrued interest directed to AFBCWF. - HC
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TaxTMI 
TaxTMI 
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