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...
ECIR is an internal, non-statutory departmental record that neither initiates prosecution nor independently imposes penal consequences. A first-instance acquittal in a scheduled offence is not final absolution while subject to appeal and does not determine the legitimacy of separately seized assets. The PMLA's specialised adjudicatory and appellate mechanism governs property retention and confiscation; writ jurisdiction should not bypass it where disputed financial facts require evidentiary assessment. Material indicating contravention of another law must be shared with the relevant agency under section 66(2), independently of an acquittal in a distinct predicate proceeding. The writ petition was dismissed, leaving statutory remedies available.
ECIR is an internal, non-statutory departmental record that neither initiates prosecution nor independently imposes penal consequences. A first-instance acquittal in a scheduled offence is not final absolution while subject to appeal and does not determine the legitimacy of separately seized assets. The PMLA's specialised adjudicatory and appellate mechanism governs property retention and confiscation; writ jurisdiction should not bypass it where disputed financial facts require evidentiary assessment. Material indicating contravention of another law must be shared with the relevant agency under section 66(2), independently of an acquittal in a distinct predicate proceeding. The writ petition was dismissed, leaving statutory remedies available.
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