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...
Provisional attachment under the Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
Provisional attachment under the Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
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