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Supreme Court of India 2022-08-23 allowed

UNION OF INDIA & ANR vs M/s. GANPATI DEALCOM PVT. LTD

Bench: 3 — N.V. Ramana, Krishna Murari, Hima Kohli

In Brief

A company purchased property in 2011 for Rs.9.44 crores using its capital. After a shareholding change in 2012, tax authorities issued a notice in 2017 claiming the property was "benami" (held in another's name) under the amended Benami Transactions Act, 2016. The Supreme Court held that the 2016 Amendment Act is prospective only, not retrospective. Sections of the 1988 Act creating criminal liability and property confiscation were unconstitutional for lacking safeguards and being manifestly arbitrary. Since confiscation is punitive in nature, it cannot apply retroactively to pre-2016 transactions under Article 20(1) of the Constitution. All prosecutions and confiscation proceedings for transactions before 25 October 2016 are quashed.

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Constitutional Law Criminal Law Property Law Benami Transactions Article 20 - Protection against Ex Facto Laws Manifest Arbitrariness Confiscation and Forfeiture Retrospective and Prospective Legislation Substantive Due Process

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