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...
The AT dismissed the appeal and upheld the provisional attachment of 68% of the immovable property, concluding that the PMLA amendments effective 15.02.2013 applied and that enforcement action was lawfully initiated post-amendment (ECIR registered 27.10.2015; PAO issued 26.07.2018, confirmed 11.01.2019). The Tribunal found sufficient evidence that the appellant knowingly handled proceeds of crime-cash deposits, inconsistent explanations about sales and transport, and reliance on false documentation-yielding identified laundered proceeds of Rs. 11,41,800.00. Reliance on contrary interim orders and family-settlement title were rejected; proceedings under the PMLA and attachment were sustained as legally valid and proportionate.
The AT dismissed the appeal and upheld the provisional attachment of 68% of the immovable property, concluding that the PMLA amendments effective 15.02.2013 applied and that enforcement action was lawfully initiated post-amendment (ECIR registered 27.10.2015; PAO issued 26.07.2018, confirmed 11.01.2019). The Tribunal found sufficient evidence that the appellant knowingly handled proceeds of crime-cash deposits, inconsistent explanations about sales and transport, and reliance on false documentation-yielding identified laundered proceeds of Rs. 11,41,800.00. Reliance on contrary interim orders and family-settlement title were rejected; proceedings under the PMLA and attachment were sustained as legally valid and proportionate.
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