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...
The Tribunal interpreted "proceeds of crime" to include not only property directly or indirectly derived from a scheduled offence, but also property of equivalent value where the actual tainted property is unavailable. On that construction, provisional attachment can extend to immovable properties acquired before the check-period or even before commission of the offence, because the relevant question is whether equivalent-value attachment secures quantified proceeds of crime. The check-period used for assessing disproportionate assets was held to be distinct from the period relevant to attachment. As the value of the attached properties remained below the quantified proceeds of crime, the confirmation of provisional attachment was upheld.
The Tribunal interpreted "proceeds of crime" to include not only property directly or indirectly derived from a scheduled offence, but also property of equivalent value where the actual tainted property is unavailable. On that construction, provisional attachment can extend to immovable properties acquired before the check-period or even before commission of the offence, because the relevant question is whether equivalent-value attachment secures quantified proceeds of crime. The check-period used for assessing disproportionate assets was held to be distinct from the period relevant to attachment. As the value of the attached properties remained below the quantified proceeds of crime, the confirmation of provisional attachment was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
