Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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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