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...
Quashing of an FIR against one accused does not automatically invalidate parallel PMLA investigation, ECIR recording or provisional attachment where predicate offences remain disclosed and proceedings against other persons continue; the continuation of proceedings and attachment was therefore sustained. Transfers routed through a web of companies were held to be paper/shell transactions in the absence of loan documentation, balance sheet entries or supporting books, and contemporaneous material traced the money trail to disputed properties. Under the statutory allocation of burden (notice obligations and the onus under Section 24), appellants failed to disclose or prove lawful source of funds, justifying confirmation of provisional attachment.
Quashing of an FIR against one accused does not automatically invalidate parallel PMLA investigation, ECIR recording or provisional attachment where predicate offences remain disclosed and proceedings against other persons continue; the continuation of proceedings and attachment was therefore sustained. Transfers routed through a web of companies were held to be paper/shell transactions in the absence of loan documentation, balance sheet entries or supporting books, and contemporaneous material traced the money trail to disputed properties. Under the statutory allocation of burden (notice obligations and the onus under Section 24), appellants failed to disclose or prove lawful source of funds, justifying confirmation of provisional attachment.
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