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ITR Can’t Whitewash Crime Proceeds – Tribunal Upholds ED Attachment

Case Law Details

TaxGuru Citation
2025 taxguru.in 10369
Case Name
Chandrama Prasad Singh Vs Deputy Director (Appellate Tribunal Under SAFEMA Delhi)
Date of Judgement/Order
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Chandrama Prasad Singh Vs Deputy Director (Appellate Tribunal Under SAFEMA Delhi)

ITR Can’t Whitewash Crime Proceeds – Tribunal Upholds ED Attachment- Land Mafia’s Properties Worth ₹4 Crore Confirmed as Proceeds of Crime

A batch of appeals was filed challenging the Adjudicating Authority’s order dated 09.09.2022, which had confirmed the provisional attachment order dated 31.03.2022 under the Prevention of Money Laundering Act, 2002 (PMLA).

Background of the Case

The Enforcement Directorate (ED), Patna recorded an ECIR based on multiple FIRs against the appellants.

1. FIR No. 95/2007 (u/s 302 IPC & others) concerned the murder for which Chandrama Prasad Singh was charge-sheeted.

2. FIR No. 68/2012 (u/s 147, 148, 149, 385, 354, 379, 323, 307, 504, 506 IPC) involved allegations of extortion of ₹5 lakh, assault, & snatching of ornaments.

ED’s investigation revealed that the accused & their family members were habitual offenders engaged in extortion, cheating, & fraudulent land deals. They allegedly acquired immovable & movable properties worth ₹4.04 crore from tainted money, projecting it as legitimate. Frequent cash deposits exceeding ₹2.7 crore were detected in various accounts of Chandrama Prasad Singh, his relatives & associates. Their declared incomes were meagre — e.g., ₹75,600 in FY 2012-13, ₹4.47 lakh in 2013-14, ₹6.55 lakh in 2015-16 — without any supporting proof of business or profession.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,232

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