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 a PAO was upheld on the basis that available investigative material, including recovered bribe money and an unquashed FIR, established a prima facie case of money laundering; the appellant's contention that no crime was committed was rejected. The Tribunal directed that attachment must be limited to quantifiable proceeds of crime rather than the entire contract value, recognising legitimate manufacturing costs and expenses. The respondent was ordered to quantify the recoverable proceeds (focusing on the profit/illicit portion) and reassess the provisional attachment within the specified four week period.
Provisional attachment under a PAO was upheld on the basis that available investigative material, including recovered bribe money and an unquashed FIR, established a prima facie case of money laundering; the appellant's contention that no crime was committed was rejected. The Tribunal directed that attachment must be limited to quantifiable proceeds of crime rather than the entire contract value, recognising legitimate manufacturing costs and expenses. The respondent was ordered to quantify the recoverable proceeds (focusing on the profit/illicit portion) and reassess the provisional attachment within the specified four week period.
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