Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
The note addresses provisional attachment in disproportionate assets proceedings, emphasising that the appellant bore the burden to prove lawful sources of funds under Section 24 of the relevant Act and failed to do so, so the attachment was sustained. The tribunal accepted valuation used for asset assessment and held that even if some property values were conservatively assessed, higher valuations would only increase alleged disproportion. Repeated unexplained cash deposits across family bank accounts were treated as unexplained proceeds relevant to the attachment. Absent credible documentary proof of income or sources, the impugned provisional attachment order was not interfered with and the appeals were dismissed.
The note addresses provisional attachment in disproportionate assets proceedings, emphasising that the appellant bore the burden to prove lawful sources of funds under Section 24 of the relevant Act and failed to do so, so the attachment was sustained. The tribunal accepted valuation used for asset assessment and held that even if some property values were conservatively assessed, higher valuations would only increase alleged disproportion. Repeated unexplained cash deposits across family bank accounts were treated as unexplained proceeds relevant to the attachment. Absent credible documentary proof of income or sources, the impugned provisional attachment order was not interfered with and the appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
