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...
The HC refused the Income Tax Department's application to appropriate fixed deposit receipts seized from Respondents pending a PMLA investigation, holding the seized funds are prima facie proceeds of crime rather than taxable income. Applying statutory definitions and the dominant-purpose analysis, the court determined that PMLA's forfeiture and restoration objectives prevail over revenue recovery where the character of the funds is under criminal adjudication. Consequently, the IT Dept may not treat or appropriate the FDR amounts as income for tax recovery until conclusion of the PMLA trial and related criminal adjudication; the Department's application was dismissed and the petition rejected.
The HC refused the Income Tax Department's application to appropriate fixed deposit receipts seized from Respondents pending a PMLA investigation, holding the seized funds are prima facie proceeds of crime rather than taxable income. Applying statutory definitions and the dominant-purpose analysis, the court determined that PMLA's forfeiture and restoration objectives prevail over revenue recovery where the character of the funds is under criminal adjudication. Consequently, the IT Dept may not treat or appropriate the FDR amounts as income for tax recovery until conclusion of the PMLA trial and related criminal adjudication; the Department's application was dismissed and the petition rejected.
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