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 text addresses provisional attachment of property alleged to be purchased using proceeds of crime through a bank loan, focusing on beneficial ownership and benami transactions. It explains that accommodated LC discounting transactions were used to generate illicit funds, that recorded witness statements implicated the arranger and beneficiaries, and that loan disbursement and EMI repayments were effected by unexplained cash deposits traced to the arranger. On that factual matrix the adjudicating authority confirmed attachment and the appeal was dismissed.
The text addresses provisional attachment of property alleged to be purchased using proceeds of crime through a bank loan, focusing on beneficial ownership and benami transactions. It explains that accommodated LC discounting transactions were used to generate illicit funds, that recorded witness statements implicated the arranger and beneficiaries, and that loan disbursement and EMI repayments were effected by unexplained cash deposits traced to the arranger. On that factual matrix the adjudicating authority confirmed attachment and the appeal was dismissed.
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