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...
Proceeds of crime includes the value of tainted property and its equivalent, permitting provisional attachment even if the property holder is not accused; the tribunal applied the 'value of any such property' limb and treated bank deposits, confessional statements and corroborative seizures as sufficient material to form 'reason to believe', rejecting explanations of family transactions. The adjudicatory finding that unexplained income, expenditure and investments, together with seized cash and gold and transactional patterns, justified confirmation of provisional attachment was sustained and the appeal dismissed for lack of merit.
Proceeds of crime includes the value of tainted property and its equivalent, permitting provisional attachment even if the property holder is not accused; the tribunal applied the 'value of any such property' limb and treated bank deposits, confessional statements and corroborative seizures as sufficient material to form 'reason to believe', rejecting explanations of family transactions. The adjudicatory finding that unexplained income, expenditure and investments, together with seized cash and gold and transactional patterns, justified confirmation of provisional attachment was sustained and the appeal dismissed for lack of merit.
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