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...
Attachment under the Act is not limited to property directly derived from the scheduled offence and may extend to property of equivalent value where the actual proceeds of crime are not traceable or available. The Tribunal held that, on the facts, unauthorized deposits were collected and diverted, and the tainted funds had been layered and siphoned off, justifying attachment of immovable properties standing in the appellants' names. It rejected the contention that property acquired before the offence is always immune, since that reading would make the statutory concept of value-equivalent attachment redundant. The challenge to the provisional attachment therefore failed and confirmation of attachment was sustained.
Attachment under the Act is not limited to property directly derived from the scheduled offence and may extend to property of equivalent value where the actual proceeds of crime are not traceable or available. The Tribunal held that, on the facts, unauthorized deposits were collected and diverted, and the tainted funds had been layered and siphoned off, justifying attachment of immovable properties standing in the appellants' names. It rejected the contention that property acquired before the offence is always immune, since that reading would make the statutory concept of value-equivalent attachment redundant. The challenge to the provisional attachment therefore failed and confirmation of attachment was sustained.
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