Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
PMLA proceedings require a subsisting scheduled offence and proceeds of crime derived from criminal activity relating to that offence. Where the predicate FIR ended through acceptance of a cancellation report and dismissal of the protest petition, continuation of the ECIR and coercive measures based solely on that FIR lacked jurisdiction, subject to possible revival if the predicate investigation is revived. Pre-prosecution PMLA search, seizure, freezing and attachment actions remain in the civil or executive stream and may be challenged through civil writ jurisdiction. The Adjudicating Authority's remedies address consequential measures, not the foundational validity of an ECIR. An addendum cannot revive an ECIR that has lost its predicate basis, particularly where it relies on materially distinct allegations and may constitute a colourable exercise of power.
PMLA proceedings require a subsisting scheduled offence and proceeds of crime derived from criminal activity relating to that offence. Where the predicate FIR ended through acceptance of a cancellation report and dismissal of the protest petition, continuation of the ECIR and coercive measures based solely on that FIR lacked jurisdiction, subject to possible revival if the predicate investigation is revived. Pre-prosecution PMLA search, seizure, freezing and attachment actions remain in the civil or executive stream and may be challenged through civil writ jurisdiction. The Adjudicating Authority's remedies address consequential measures, not the foundational validity of an ECIR. An addendum cannot revive an ECIR that has lost its predicate basis, particularly where it relies on materially distinct allegations and may constitute a colourable exercise of power.
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