Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Retention of seized jewellery under PMLA was sustained because interlinked accounts, fund movements and jewellery payments supplied a prima facie nexus with proceeds of crime. The inquiry may cover property held by a person not accused of the scheduled offence where the property is connected with, or requires examination regarding, such proceeds. Recovery from a joint family residence and lack of transaction-wise tracing for individual items did not negate the nexus. Defective initial service of notice did not invalidate adjudication because participation and opportunity to defend caused no identified prejudice.
Retention of seized jewellery under PMLA was sustained because interlinked accounts, fund movements and jewellery payments supplied a prima facie nexus with proceeds of crime. The inquiry may cover property held by a person not accused of the scheduled offence where the property is connected with, or requires examination regarding, such proceeds. Recovery from a joint family residence and lack of transaction-wise tracing for individual items did not negate the nexus. Defective initial service of notice did not invalidate adjudication because participation and opportunity to defend caused no identified prejudice.
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