Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
Note: It is a system-generated summary and is for quick reference only.