Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
The Tribunal held that the dominant issue was whether property acquired before the predicate offence could be provisionally attached as "proceeds of crime" under Section 2(1)(u). Applying the second limb of the definition-where original proceeds are not traceable-the authority may attach property of equivalent value; precedent support was invoked. The challenge to jurisdictional change and denial of physical hearing was rejected because virtual hearing provided adequate opportunity and the appellant declined it, so no breach of natural justice. Factual findings that a portion of funds remained unreturned sustained the attachment. Appeals dismissed. - AT
The Tribunal held that the dominant issue was whether property acquired before the predicate offence could be provisionally attached as "proceeds of crime" under Section 2(1)(u). Applying the second limb of the definition-where original proceeds are not traceable-the authority may attach property of equivalent value; precedent support was invoked. The challenge to jurisdictional change and denial of physical hearing was rejected because virtual hearing provided adequate opportunity and the appellant declined it, so no breach of natural justice. Factual findings that a portion of funds remained unreturned sustained the attachment. Appeals dismissed. - AT
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