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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
