PMLA inquiry and attachment can proceed without a predicate FIR; ECIR remains an internal record.

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Full Text of the Document

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....PMLA inquiry and civil action are described as not depending on prior registration of a predicate FIR or complaint: the ECIR is characterised as a non-statutory internal record, so quashing it is said to be misconceived, and summons under Section 50 are treated as part of the Act's inquiry and evidentiary machinery rather than prosecution. The text distinguishes the civil and penal limbs of the PMLA, stating that provisional attachment and related inquiry may proceed to secure proceeds of crime even where the scheduled offence FIR is not yet registered, with information to be shared under Section 66(2). It also states that income-tax settlement immunity does not bar independent PMLA proceedings; the appeal was dismissed.....