Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
The AT dismissed all appeals challenging the provisional attachment orders under the Prevention of Money Laundering Act. The appellants failed to satisfactorily disclose legitimate sources for the funds used to acquire properties or repay loans, with statements under Section 50(2) of the Act corroborating the involvement of proceeds of crime. The tribunal found that the properties and transactions were part of layering operations orchestrated by the main accused to conceal illicit funds. Despite claims of gifts and income, appellants could not provide adequate documentary evidence or credible explanations to rebut the attachment. The respondent's actions in attaching properties and bank accounts linked to the accused and their relatives were held to be justified. No interference was warranted with the provisional attachment orders, as the material on record supported the conclusion that the assets were proceeds of crime.
The AT dismissed all appeals challenging the provisional attachment orders under the Prevention of Money Laundering Act. The appellants failed to satisfactorily disclose legitimate sources for the funds used to acquire properties or repay loans, with statements under Section 50(2) of the Act corroborating the involvement of proceeds of crime. The tribunal found that the properties and transactions were part of layering operations orchestrated by the main accused to conceal illicit funds. Despite claims of gifts and income, appellants could not provide adequate documentary evidence or credible explanations to rebut the attachment. The respondent's actions in attaching properties and bank accounts linked to the accused and their relatives were held to be justified. No interference was warranted with the provisional attachment orders, as the material on record supported the conclusion that the assets were proceeds of crime.
Note: It is a system-generated summary and is for quick reference only.