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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FERA contraventions require the Department to prove both the recovery of currency and its nexus with unauthorised foreign-exchange dealings. Unexamined panch witnesses and a doubtful panchnama left the alleged recovery unproved, while mere possession of currency did not displace a reasonable explanation based on bank and cash-book records. The statutory presumption for seized documents applies only to otherwise admissible material; loose sheets are not books of account and could not be relied upon. A retracted statement requires proof of voluntariness and independent corroboration. The burden to prove permission arises only after proof of an act requiring permission. Penalties and confiscation were set aside, and the appeal was dismissed.
FERA contraventions require the Department to prove both the recovery of currency and its nexus with unauthorised foreign-exchange dealings. Unexamined panch witnesses and a doubtful panchnama left the alleged recovery unproved, while mere possession of currency did not displace a reasonable explanation based on bank and cash-book records. The statutory presumption for seized documents applies only to otherwise admissible material; loose sheets are not books of account and could not be relied upon. A retracted statement requires proof of voluntariness and independent corroboration. The burden to prove permission arises only after proof of an act requiring permission. Penalties and confiscation were set aside, and the appeal was dismissed.
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