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 under the Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
Provisional attachment under the Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
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