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...
Attachment of property under PMLA is discussed in the context of alleged proceeds of crime arising from scheduled offences, where the Adjudicating Authority issued a show cause notice on the basis of the original complaint, relied-upon documents and statements under section 50, and later confirmed the provisional attachment. The appeals were carried to the Appellate Tribunal under SAFEMA. A specific contention noted in the source is that attachment of property acquired before 01-07-2005, the commencement of PMLA, is not valid in law; the Tribunal is stated to have dealt with that issue along with the other grounds raised.
Attachment of property under PMLA is discussed in the context of alleged proceeds of crime arising from scheduled offences, where the Adjudicating Authority issued a show cause notice on the basis of the original complaint, relied-upon documents and statements under section 50, and later confirmed the provisional attachment. The appeals were carried to the Appellate Tribunal under SAFEMA. A specific contention noted in the source is that attachment of property acquired before 01-07-2005, the commencement of PMLA, is not valid in law; the Tribunal is stated to have dealt with that issue along with the other grounds raised.
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