Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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Vesting of title on confiscation: the Court held that once confiscation is ordered under Section 130(1) and title vests in the State under Section 130(5), the remedial release regime under Section 129 is no longer available; subsequent adjudication on confiscation, valuation, tax, penalty, interest and fine is governed exclusively by Section 130, and a collateral challenge limited to a prior Section 129 order is impermissible where the Section 130 order remains unchallenged. The Single Judge erred in ordering release; the writ is set aside and the respondent must pursue the statutory appeal under Section 107(6) with prescribed pre-deposit terms.
Vesting of title on confiscation: the Court held that once confiscation is ordered under Section 130(1) and title vests in the State under Section 130(5), the remedial release regime under Section 129 is no longer available; subsequent adjudication on confiscation, valuation, tax, penalty, interest and fine is governed exclusively by Section 130, and a collateral challenge limited to a prior Section 129 order is impermissible where the Section 130 order remains unchallenged. The Single Judge erred in ordering release; the writ is set aside and the respondent must pursue the statutory appeal under Section 107(6) with prescribed pre-deposit terms.
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