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...
Reverse burden under the 2002 Act applied once foundational facts showed the appellant's active connection with the entities and possession of loan and utilisation documents, so he had to displace the statutory presumption regarding proceeds of crime. The Tribunal held that he was not a mere nominal director and could not rely on liability principles from other statutes. It also required him to prove the lawful source of money in the frozen bank accounts under Section 8(1). His unsupported claim of income from a gym business and LIC commission failed, so retention of seized documents and devices, and continuance of the account freeze, were upheld.
Reverse burden under the 2002 Act applied once foundational facts showed the appellant's active connection with the entities and possession of loan and utilisation documents, so he had to displace the statutory presumption regarding proceeds of crime. The Tribunal held that he was not a mere nominal director and could not rely on liability principles from other statutes. It also required him to prove the lawful source of money in the frozen bank accounts under Section 8(1). His unsupported claim of income from a gym business and LIC commission failed, so retention of seized documents and devices, and continuance of the account freeze, were upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
