Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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The Tribunal discussed PMLA attachment where the money trail showed circulation of funds through group companies, paper entities and restructuring arrangements, and held that such routing could constitute layering and proceeds of crime. It rejected explanations based on surplus funds, security deposits, home loans or corporate debt restructuring when unsupported by records, and noted that the burden to disprove taint lay on the claimant. It also accepted equivalent value attachment where diverted funds were no longer available and sustained provisional attachment of properties, subject to the final outcome of trial.
The Tribunal discussed PMLA attachment where the money trail showed circulation of funds through group companies, paper entities and restructuring arrangements, and held that such routing could constitute layering and proceeds of crime. It rejected explanations based on surplus funds, security deposits, home loans or corporate debt restructuring when unsupported by records, and noted that the burden to disprove taint lay on the claimant. It also accepted equivalent value attachment where diverted funds were no longer available and sustained provisional attachment of properties, subject to the final outcome of trial.
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