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 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.
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TaxTMI 
TaxTMI 
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