Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
AT determined that provisional property attachment under PMLA was invalid where appellants lacked possession of crime proceeds. While "proceeds of crime" broadly encompasses property derived directly/indirectly from criminal activity and equivalent-value property, authorities must establish actual possession or likelihood of concealment/transfer. The tribunal found no evidence that appellants held proceeds or intended to transfer them. Additionally, pre-existing Company Law Board restrictions already prevented property transfers without Conciliation Board consent. The appeal challenging the attachment failed as authorities could not demonstrate the basic statutory requirements u/s 5(1) PMLA regarding possession or control of proceeds of crime. Appeal dismissed with the finding that mere theoretical connection to proceeds is insufficient for provisional attachment.
AT determined that provisional property attachment under PMLA was invalid where appellants lacked possession of crime proceeds. While "proceeds of crime" broadly encompasses property derived directly/indirectly from criminal activity and equivalent-value property, authorities must establish actual possession or likelihood of concealment/transfer. The tribunal found no evidence that appellants held proceeds or intended to transfer them. Additionally, pre-existing Company Law Board restrictions already prevented property transfers without Conciliation Board consent. The appeal challenging the attachment failed as authorities could not demonstrate the basic statutory requirements u/s 5(1) PMLA regarding possession or control of proceeds of crime. Appeal dismissed with the finding that mere theoretical connection to proceeds is insufficient for provisional attachment.
Note: It is a system-generated summary and is for quick reference only.