Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Provisional attachment under the PMLA was confirmed on the basis that cumulative material - statements under section 50(2) PMLA, searches, bank and property linkages and a disclosed modus operandi - established receipt and layering of proceeds of crime, with a statement under the Income Tax Act admitted only as corroboration. Objection that Regulation 3 language requirements were breached was rejected on factual findings that English translations and gists were furnished and witnesses understood Bengali. The Tribunal construed provisional attachment as permissible during investigation or related proceedings and upheld attachment of assets in individual and corporate names where material showed beneficiaries of laundering through corporate vehicles.
Provisional attachment under the PMLA was confirmed on the basis that cumulative material - statements under section 50(2) PMLA, searches, bank and property linkages and a disclosed modus operandi - established receipt and layering of proceeds of crime, with a statement under the Income Tax Act admitted only as corroboration. Objection that Regulation 3 language requirements were breached was rejected on factual findings that English translations and gists were furnished and witnesses understood Bengali. The Tribunal construed provisional attachment as permissible during investigation or related proceedings and upheld attachment of assets in individual and corporate names where material showed beneficiaries of laundering through corporate vehicles.
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