Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
The Tribunal held that the 180-day period for provisional attachment was saved by exclusion of the Covid-19 period from 15.03.2020 to 28.02.2022, so the impugned orders were within time. It rejected challenges to maintainability, finding the predicate offence and money-laundering allegations supported by the FIR, ECIR, money trail, statements, and unexplained diversion of funds, while the Supreme Court interim order did not bar attachment proceedings. It further held that the appellants failed to prove a legitimate source for jewellery and immovable properties in family members' names, and that Section 8(3) empowers retention or continuation of freezing without a prior Section 20 order. All appeals were dismissed.
The Tribunal held that the 180-day period for provisional attachment was saved by exclusion of the Covid-19 period from 15.03.2020 to 28.02.2022, so the impugned orders were within time. It rejected challenges to maintainability, finding the predicate offence and money-laundering allegations supported by the FIR, ECIR, money trail, statements, and unexplained diversion of funds, while the Supreme Court interim order did not bar attachment proceedings. It further held that the appellants failed to prove a legitimate source for jewellery and immovable properties in family members' names, and that Section 8(3) empowers retention or continuation of freezing without a prior Section 20 order. All appeals were dismissed.
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