Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The principal issue was whether provisional attachment of corporate properties was lawful as proceeds of crime were allegedly injected into the company via purchase of share warrants, subsequent conversion to equity, and loans routed through NBFCs controlled by the accused. The tribunal relied on detailed factual money-trail in the original complaint identifying extensive related entities and payments (including an additional payment of Rs. 39.75 crores) and found loans, even if repaid, originated from tainted funds; consequently the attachment was lawful and the appeals were dismissed. - AT
The principal issue was whether provisional attachment of corporate properties was lawful as proceeds of crime were allegedly injected into the company via purchase of share warrants, subsequent conversion to equity, and loans routed through NBFCs controlled by the accused. The tribunal relied on detailed factual money-trail in the original complaint identifying extensive related entities and payments (including an additional payment of Rs. 39.75 crores) and found loans, even if repaid, originated from tainted funds; consequently the attachment was lawful and the appeals were dismissed. - AT
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