Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
PMLA attachment preceding a compromise decree takes priority where ownership has not been transferred in execution of the compromise terms; the decree does not create rights in the attached property. A single Member (Finance) may validly confirm attachment because the statutory scheme permits a single-member bench with appellate review on facts and law. Property acquired before the scheduled offence is not automatically immune from attachment if it constitutes proceeds of crime. Provisional attachment requires recorded reasons to believe that immediate action is necessary, while challenges to the factual basis of that satisfaction are to follow statutory appellate remedies. Confirmation also requires the Adjudicating Authority to independently assess material and form the requisite belief.
PMLA attachment preceding a compromise decree takes priority where ownership has not been transferred in execution of the compromise terms; the decree does not create rights in the attached property. A single Member (Finance) may validly confirm attachment because the statutory scheme permits a single-member bench with appellate review on facts and law. Property acquired before the scheduled offence is not automatically immune from attachment if it constitutes proceeds of crime. Provisional attachment requires recorded reasons to believe that immediate action is necessary, while challenges to the factual basis of that satisfaction are to follow statutory appellate remedies. Confirmation also requires the Adjudicating Authority to independently assess material and form the requisite belief.
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