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...
Construction of "proceeds of crime" and the offence under the PMLA was examined against allegations of large-scale illegal quarrying and related lease transactions; the court applied statutory definitions and precedents to hold that the complaint furnishes prima facie particulars linking the impugned property and lease dealings to laundering and thus discloses offences under the money laundering statute. Acquisition of property before the predicate offences was held not determinative where the complaint pleads subsequent use, transfer or lease for concealment and laundering. The extraordinary jurisdiction to quash was declined and the petition was dismissed; issues reserved for trial.
Construction of "proceeds of crime" and the offence under the PMLA was examined against allegations of large-scale illegal quarrying and related lease transactions; the court applied statutory definitions and precedents to hold that the complaint furnishes prima facie particulars linking the impugned property and lease dealings to laundering and thus discloses offences under the money laundering statute. Acquisition of property before the predicate offences was held not determinative where the complaint pleads subsequent use, transfer or lease for concealment and laundering. The extraordinary jurisdiction to quash was declined and the petition was dismissed; issues reserved for trial.
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