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 of properties was upheld on the material and recorded admissions showing appellants promoted and collected deposits for illicit schemes and acquired property from those proceeds; the Adjudicating Authority's confirmation therefore required no interference. The tribunal accepted that remuneration, salary or commission earned by persons acting as instruments to procure funds for unlicensed fraudulent schemes constitutes proceeds of crime and may be attached. Properties held by spouses or other recipients were also subject to provisional attachment where evidence showed acquisition from the proceeds and recipients could not demonstrate independent sources. The appeals against confirmation of attachment were dismissed.
Provisional attachment of properties was upheld on the material and recorded admissions showing appellants promoted and collected deposits for illicit schemes and acquired property from those proceeds; the Adjudicating Authority's confirmation therefore required no interference. The tribunal accepted that remuneration, salary or commission earned by persons acting as instruments to procure funds for unlicensed fraudulent schemes constitutes proceeds of crime and may be attached. Properties held by spouses or other recipients were also subject to provisional attachment where evidence showed acquisition from the proceeds and recipients could not demonstrate independent sources. The appeals against confirmation of attachment were dismissed.
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TaxTMI 
TaxTMI 
of 4918 
