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Appreciation Value Under PMLA: If a Property Bought for ₹20 Lakh Is Now Worth ₹2 Crore, Can ED Attach the Entire Current Value?

A property purchased for ₹20 lakh may later be worth ₹2 crore, but PMLA does not permit every valuation question to be answered simply by taking today's market price. If the property itself was wholly acquired from alleged proceeds of crime, the Delhi High Court's 2025 Prakash Industries reasoning supports the proposition that appreciation generated from a tainted investment does not become clean merely because market forces increased its value. But where ED attaches a clean substitute property as “value of any such property”, Section 2(1)(zb) defines value with reference to fair market value

Premium21 Aug 202619 min readCriminal DefencePMLAED SummonsECIRProvisional Attachment
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Appreciation Value Under PMLA: If a Property Bought for ₹20 Lakh Is Now Worth ₹2 Crore, Can ED Attach the Entire Current Value?

A property purchased for ₹20 lakh may later be worth ₹2 crore, but PMLA does not permit every valuation question to be answered simply by taking today's market price. If the property itself was wholly acquired from alleged proceeds of crime, the Delhi High Court's 2025 Prakash Industries reasoning supports the proposition that appreciation generated from a tainted investment does not become clean merely because market forces increased its value. But where ED attaches a clean substitute property as “value of any such property”, Section 2(1)(zb) defines value with reference to fair market value

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