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 PMLA can extend to property of equivalent value where the original proceeds of crime are unavailable, even if the attached property was acquired before the alleged offence; the attachment was upheld on that basis. Pendency of a challenge to the predicate offence before the Supreme Court did not by itself invalidate the attachment, because the predicate offence had not been quashed and the interim stay did not extinguish it. The Tribunal also held that provisional attachment is not confined to a person formally named as an accused in the predicate offence, if the person is otherwise involved in the offence or is a recipient of proceeds of crime. The attachment was sustained, subject to the final outcome before the Supreme Court.
Provisional attachment under PMLA can extend to property of equivalent value where the original proceeds of crime are unavailable, even if the attached property was acquired before the alleged offence; the attachment was upheld on that basis. Pendency of a challenge to the predicate offence before the Supreme Court did not by itself invalidate the attachment, because the predicate offence had not been quashed and the interim stay did not extinguish it. The Tribunal also held that provisional attachment is not confined to a person formally named as an accused in the predicate offence, if the person is otherwise involved in the offence or is a recipient of proceeds of crime. The attachment was sustained, subject to the final outcome before the Supreme Court.
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