Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
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The Tribunal held that the 180-day period for provisional attachment was saved by exclusion of the Covid-19 period from 15.03.2020 to 28.02.2022, so the impugned orders were within time. It rejected challenges to maintainability, finding the predicate offence and money-laundering allegations supported by the FIR, ECIR, money trail, statements, and unexplained diversion of funds, while the Supreme Court interim order did not bar attachment proceedings. It further held that the appellants failed to prove a legitimate source for jewellery and immovable properties in family members' names, and that Section 8(3) empowers retention or continuation of freezing without a prior Section 20 order. All appeals were dismissed.
The Tribunal held that the 180-day period for provisional attachment was saved by exclusion of the Covid-19 period from 15.03.2020 to 28.02.2022, so the impugned orders were within time. It rejected challenges to maintainability, finding the predicate offence and money-laundering allegations supported by the FIR, ECIR, money trail, statements, and unexplained diversion of funds, while the Supreme Court interim order did not bar attachment proceedings. It further held that the appellants failed to prove a legitimate source for jewellery and immovable properties in family members' names, and that Section 8(3) empowers retention or continuation of freezing without a prior Section 20 order. All appeals were dismissed.
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