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 is an interim protective measure to preserve property for possible confiscation and may be confirmed even where the seized currency/FDR is held in custody by a trial court; mere custody does not preclude confirmation and legally entitled persons may claim return if acquitted. Registration of FIR, filing of charge-sheet and corroborative materials (voluntary disclosures, recorded conversations) furnish prima facie 'reason to believe' supporting attachment. The respondents' plea that seized cash were sale proceeds is an issue for trial and does not defeat confirmation. The provisional attachment was confirmed without prejudice to criminal trial rights.
Provisional attachment under the PMLA is an interim protective measure to preserve property for possible confiscation and may be confirmed even where the seized currency/FDR is held in custody by a trial court; mere custody does not preclude confirmation and legally entitled persons may claim return if acquitted. Registration of FIR, filing of charge-sheet and corroborative materials (voluntary disclosures, recorded conversations) furnish prima facie 'reason to believe' supporting attachment. The respondents' plea that seized cash were sale proceeds is an issue for trial and does not defeat confirmation. The provisional attachment was confirmed without prejudice to criminal trial rights.
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