Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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Money-laundering is treated as an independent and continuing offence, so attachment under the PMLA turns on the date when proceeds of crime are possessed, concealed, used, or projected as untainted property, not on the date of the loan or predicate offence. The definition of proceeds of crime was read to include equivalent value property, allowing attachment of assets acquired earlier when traced tainted property is unavailable. Settlement of bank dues did not displace attachment while the predicate offence remained pending, and property could be attached in the hands of third parties, including a wife or children, if it represented proceeds of crime. The attachment was upheld in full.
Money-laundering is treated as an independent and continuing offence, so attachment under the PMLA turns on the date when proceeds of crime are possessed, concealed, used, or projected as untainted property, not on the date of the loan or predicate offence. The definition of proceeds of crime was read to include equivalent value property, allowing attachment of assets acquired earlier when traced tainted property is unavailable. Settlement of bank dues did not displace attachment while the predicate offence remained pending, and property could be attached in the hands of third parties, including a wife or children, if it represented proceeds of crime. The attachment was upheld in full.
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