Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Quashing of predicate proceedings for lack of investigative jurisdiction removes the subsisting nexus required between alleged proceeds of crime and criminal activity relating to a scheduled offence. Where the predicate prosecution against a person is quashed in its entirety, and that order remains operative and unchallenged, the Enforcement Directorate cannot independently preserve or notionally revive the predicate offence for money-laundering proceedings. Proceedings against other accused cannot establish the missing statutory nexus attributable to that person. PMLA summons and consequential proceedings were quashed, with liberty to initiate fresh proceedings if the predicate prosecution is lawfully restored or revived.
Quashing of predicate proceedings for lack of investigative jurisdiction removes the subsisting nexus required between alleged proceeds of crime and criminal activity relating to a scheduled offence. Where the predicate prosecution against a person is quashed in its entirety, and that order remains operative and unchallenged, the Enforcement Directorate cannot independently preserve or notionally revive the predicate offence for money-laundering proceedings. Proceedings against other accused cannot establish the missing statutory nexus attributable to that person. PMLA summons and consequential proceedings were quashed, with liberty to initiate fresh proceedings if the predicate prosecution is lawfully restored or revived.
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