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 impugned provisional attachment order under the PMLA. The Tribunal found that antecedent findings during investigation and a pending prosecution complaint before the Special Court under PMLA preclude collateral quashing; disputed investigative particulars cannot be adjudicated at this interlocutory stage and require trial-level evidence appraisal. The HC's prior refusal to quash related proceedings was noted as persuasive. The Tribunal therefore affirmed continuation of the confederate provisional measures and left all factual and culpability determinations to the trial court, with liberty to the appellants to urge defenses and challenge evidence at the Special Court.
The AT dismissed the appeal and upheld the impugned provisional attachment order under the PMLA. The Tribunal found that antecedent findings during investigation and a pending prosecution complaint before the Special Court under PMLA preclude collateral quashing; disputed investigative particulars cannot be adjudicated at this interlocutory stage and require trial-level evidence appraisal. The HC's prior refusal to quash related proceedings was noted as persuasive. The Tribunal therefore affirmed continuation of the confederate provisional measures and left all factual and culpability determinations to the trial court, with liberty to the appellants to urge defenses and challenge evidence at the Special Court.
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