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...
Provisional attachment under the PMLA was upheld because investigative material furnished a reason to believe that the appellant participated in converting demonetized currency into gold/bullion, establishing a proximate link between seized currency and proceeds of crime; absence of the appellant's name in the FIR/ECIR did not bar attachment since PMLA proceedings depend on independent investigative material and statements recorded during the probe; attachment may extend to equivalent value of proceeds even where property was acquired earlier, and the prima facie case met the statutory threshold for sustaining provisional attachment.
Provisional attachment under the PMLA was upheld because investigative material furnished a reason to believe that the appellant participated in converting demonetized currency into gold/bullion, establishing a proximate link between seized currency and proceeds of crime; absence of the appellant's name in the FIR/ECIR did not bar attachment since PMLA proceedings depend on independent investigative material and statements recorded during the probe; attachment may extend to equivalent value of proceeds even where property was acquired earlier, and the prima facie case met the statutory threshold for sustaining provisional attachment.
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