Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
SC refused interlocutory relief and declined to quash cognizance or interdict ongoing proceedings under the PMLA, holding that the contention that the entire banking balance constituted "proceeds of crime" was unsustainable where transactions were routed through regular banking channels and reflected in books of account. The Court directed that the statutory process, including appellate review by the Appellate Tribunal, be permitted to run its course to determine whether the attached assets constitute "proceeds of crime" under Section 2(1)(u) and whether withdrawals contravened law. Allegations are presently confined to recovery of INR 33.80 Crore and do not presently establish criminal liability beyond the statutory process; appellants may pursue statutory appeals.
SC refused interlocutory relief and declined to quash cognizance or interdict ongoing proceedings under the PMLA, holding that the contention that the entire banking balance constituted "proceeds of crime" was unsustainable where transactions were routed through regular banking channels and reflected in books of account. The Court directed that the statutory process, including appellate review by the Appellate Tribunal, be permitted to run its course to determine whether the attached assets constitute "proceeds of crime" under Section 2(1)(u) and whether withdrawals contravened law. Allegations are presently confined to recovery of INR 33.80 Crore and do not presently establish criminal liability beyond the statutory process; appellants may pursue statutory appeals.
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