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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...
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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 dominant issue was whether property acquired prior to the commission of the scheduled offence can be provisionally attached as "proceeds of crime" on an equivalent value basis under the PMLA. Interpreting the definition as comprising multiple limbs, the forum held that the "equivalent value" limb permits attachment where the actual proceeds are untraceable or unavailable because they were siphoned off or vanished; a narrower reading would defeat the Act's object by enabling offenders to frustrate recovery. Applying binding precedent and rejecting contrary authority, the provisional attachment was upheld and the appeals were dismissed. - AT
The dominant issue was whether property acquired prior to the commission of the scheduled offence can be provisionally attached as "proceeds of crime" on an equivalent value basis under the PMLA. Interpreting the definition as comprising multiple limbs, the forum held that the "equivalent value" limb permits attachment where the actual proceeds are untraceable or unavailable because they were siphoned off or vanished; a narrower reading would defeat the Act's object by enabling offenders to frustrate recovery. Applying binding precedent and rejecting contrary authority, the provisional attachment was upheld and the appeals were dismissed. - AT
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