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...
Money-laundering is treated as an independent and continuing offence, so attachment under the PMLA turns on the date when proceeds of crime are possessed, concealed, used, or projected as untainted property, not on the date of the loan or predicate offence. The definition of proceeds of crime was read to include equivalent value property, allowing attachment of assets acquired earlier when traced tainted property is unavailable. Settlement of bank dues did not displace attachment while the predicate offence remained pending, and property could be attached in the hands of third parties, including a wife or children, if it represented proceeds of crime. The attachment was upheld in full.
Money-laundering is treated as an independent and continuing offence, so attachment under the PMLA turns on the date when proceeds of crime are possessed, concealed, used, or projected as untainted property, not on the date of the loan or predicate offence. The definition of proceeds of crime was read to include equivalent value property, allowing attachment of assets acquired earlier when traced tainted property is unavailable. Settlement of bank dues did not displace attachment while the predicate offence remained pending, and property could be attached in the hands of third parties, including a wife or children, if it represented proceeds of crime. The attachment was upheld in full.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
