Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Provisional attachment under the money-laundering regime was upheld because an interim order in the predicate criminal case did not amount to quashing, discharge, or acquittal, and therefore did not by itself invalidate a duly made attachment. The Tribunal also noted divergent views on a single-Member Adjudicating Authority coram, but treated the appeal as subject to the Supreme Court's final ruling on that question rather than allowing the objection outright. On proceeds of crime, it accepted that the definition includes the value of tainted property, so attachment may extend to property of equivalent value where the original assets have been laundered, siphoned off, or are otherwise unavailable, even if such property was acquired before the offence.
Provisional attachment under the money-laundering regime was upheld because an interim order in the predicate criminal case did not amount to quashing, discharge, or acquittal, and therefore did not by itself invalidate a duly made attachment. The Tribunal also noted divergent views on a single-Member Adjudicating Authority coram, but treated the appeal as subject to the Supreme Court's final ruling on that question rather than allowing the objection outright. On proceeds of crime, it accepted that the definition includes the value of tainted property, so attachment may extend to property of equivalent value where the original assets have been laundered, siphoned off, or are otherwise unavailable, even if such property was acquired before the offence.
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