Proceeds of crime and money laundering: PMLA prosecution requires subsisting predicate offence; discharge of predicate accused precludes further prose...
Validity of faceless assessment procedure challenged for jurisdictional AO intervention mid-remand, resulting in quashing of assessment for procedural...
The dispute concerned whether the limitation for passing a final assessment under the transfer pricing assessment procedure must be measured solely by the timeline in the specific transfer pricing provision or by reference to both that provision and the general assessment limitation provision; the tribunal concluded that the provisions are mutually inclusive and overlapping, and limitation must be determined with reference to both provisions, resulting in final assessment orders issued beyond the combined limitation period being without jurisdiction and quashed for the specified assessment years.
The dispute concerned whether the limitation for passing a final assessment under the transfer pricing assessment procedure must be measured solely by the timeline in the specific transfer pricing provision or by reference to both that provision and the general assessment limitation provision; the tribunal concluded that the provisions are mutually inclusive and overlapping, and limitation must be determined with reference to both provisions, resulting in final assessment orders issued beyond the combined limitation period being without jurisdiction and quashed for the specified assessment years.
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