PMLA proceeds prevail: Income Tax Dept barred from appropriating seized FDRs as income pending criminal adjudication

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....The HC refused the Income Tax Department's application to appropriate fixed deposit receipts seized from Respondents pending a PMLA investigation, holding the seized funds are prima facie proceeds of crime rather than taxable income. Applying statutory definitions and the dominant-purpose analysis, the court determined that PMLA's forfeiture and restoration objectives prevail over revenue recovery where the character of the funds is under criminal adjudication. Consequently, the IT Dept may not treat or appropriate the FDR amounts as income for tax recovery until conclusion of the PMLA trial and related criminal adjudication; the Department's application was dismissed and the petition rejected.....