Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
The dominant issue was whether the service agreements between regulated lenders and fintech service providers constituted proceeds of scheduled offences and unlawful outsourcing of core banking functions. The tribunal found that the co-lending structure, disguised as "performance guarantees" and revenue-sharing (service fees/minimum commitments), yielded guaranteed returns to lenders without capital deployment, and effectively outsourced core lending activities (loan sanctioning, KYC compliance and borrower management) in breach of RBI master directions; misuse of borrower data facilitated offences under IPC and IT Act. Consequence: contractual arrangements were treated as tainted and the appeal was dismissed. - AT
The dominant issue was whether the service agreements between regulated lenders and fintech service providers constituted proceeds of scheduled offences and unlawful outsourcing of core banking functions. The tribunal found that the co-lending structure, disguised as "performance guarantees" and revenue-sharing (service fees/minimum commitments), yielded guaranteed returns to lenders without capital deployment, and effectively outsourced core lending activities (loan sanctioning, KYC compliance and borrower management) in breach of RBI master directions; misuse of borrower data facilitated offences under IPC and IT Act. Consequence: contractual arrangements were treated as tainted and the appeal was dismissed. - AT
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