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...
Provisional attachment of properties was sustained because the respondent traced a money trail and layering of alleged proceeds of crime into properties, and the appellant failed to discharge the statutory burden to disclose source of funds under Section 24. The tribunal accepted that transfers from relatives, described as loans, lacked provenance and were routed through multiple bank accounts to mask cash derived from the offence; repayment of earlier loans and purchase payments were therefore treated as involving proceeds of crime. On that basis the Adjudicating Authority's confirmation of the Provisional Attachment Order was upheld and the appeal dismissed.
Provisional attachment of properties was sustained because the respondent traced a money trail and layering of alleged proceeds of crime into properties, and the appellant failed to discharge the statutory burden to disclose source of funds under Section 24. The tribunal accepted that transfers from relatives, described as loans, lacked provenance and were routed through multiple bank accounts to mask cash derived from the offence; repayment of earlier loans and purchase payments were therefore treated as involving proceeds of crime. On that basis the Adjudicating Authority's confirmation of the Provisional Attachment Order was upheld and the appeal dismissed.
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