Issues: Whether the writ challenge to the tax demand was maintainable despite the unavailed statutory appellate remedy and the allegation that the order was not communicated.

Analysis: An efficacious appeal was available under the GST enactments, but was not filed within the prescribed period. The writ petition was instituted substantially after expiry of that period. Uploading of the order on the GST portal was adequate in the circumstances, since the registered taxpayer remained registered notwithstanding cessation of business activity in the State. The record also showed issuance of notice and grant of hearing opportunity, which was not availed; hence, no breach of natural justice was established.

Conclusion: The writ challenge was not maintainable; the issue was decided against the assessee.

Issues: Whether profits of a captive power-generation undertaking for deduction under Section 80-IA(4) are to be computed using the electricity tariff charged by the electricity board to industrial consumers rather than the tariff at which the undertaking supplies surplus power to the board.

Analysis: For determining the market value of electricity transferred by captive power plants to the assessee's industrial units, the relevant open-market benchmark is the rate charged by the electricity board to industrial consumers. The tariff for surplus power supplied by a generating company to the board is regulated by contractual and statutory constraints and does not represent the price at which an industrial consumer can procure electricity in the open market. The Tribunal's direction to compute eligible profits on the consumer tariff was consistent with the settled position.

Conclusion: The consumer tariff charged by the electricity board is the market value for computing the deduction; the issue is decided in favour of the assessee and against the Revenue.

Issues: Whether the writ petition challenging the penalty proceedings, including the jurisdiction of the issuing officer and the requirement of pre-deposit, should be entertained despite an available appellate remedy before the GST Tribunal.

Analysis: The available remedy under Section 112 of the Central Goods and Services Tax Act, 2017 was held to be efficacious, as the GST Tribunal had become functional and time had been granted for filing appeals. The jurisdictional objection concerning the proper officer, the alleged breach of natural justice, and related factual matters require examination on documentary material by the Tribunal. Writ jurisdiction cannot be invoked merely to avoid the statutory pre-deposit requirement.

Outcome: The writ petition was dismissed with liberty to pursue the statutory appeal before the GST Tribunal.

Issues: Whether the Adjudicating Authority's order concerning attachment of the petitioner's bank account could stand without consideration of the petitioner's detailed objections.

Analysis: The petitioner's detailed objections to the proposed attachment were not addressed in the impugned order, although objections of other persons were considered. The respondents accepted that the petitioner's objections required consideration and an appropriate order.

Conclusion: The matter is remitted to the Adjudicating Authority for consideration of the petitioner's objections and for passing necessary orders; all other contentions remain open.

Issues: Whether reassessment proceedings can be initiated where the transactions proposed to be reassessed were specifically examined during the original scrutiny assessment.

Analysis: The original scrutiny involved specific queries and detailed replies concerning the assessee's share transactions, supported by relevant documents. The reassessment was initiated on the same material and issues already considered in the assessment completed under Section 143(3). Reopening on such material amounted to revisiting and reviewing the earlier assessment, without fresh material capable of justifying reassessment.

Conclusion: The reassessment proceedings were invalid as they were founded on a mere change of opinion, in favour of the assessee.

Issues: Whether recovery of penalty imposed under Section 271C of the Income-tax Act, 1961 should be stayed during pendency of appeals, and whether administrative guidelines restrict discretion under Section 220(6) of the Income-tax Act, 1961.

Analysis: The Court noted that the petitioner had deducted and remitted tax, though belatedly, and that the Supreme Court ruling relied upon by the petitioner indicated that Section 271C does not apply to belated deduction and remittance of tax deducted at source. Without finally deciding the scope or applicability of Section 271C, the Court found a prima facie case in favour of the petitioner. The CBDT instruction and office memoranda were treated as guidelines which did not impose a statutory fetter on the discretion under Section 220(6). Balancing the prima facie case with revenue interest, recovery was stayed subject to aggregate payment of Rs. 4 crore within the prescribed period.

Outcome: Recovery pursuant to the penalty orders was stayed until disposal of the pending appeals and for a further period of two weeks thereafter, subject to payment of Rs. 4 crore. The appeals were directed to be considered expeditiously. No final adjudication was made on the applicability of Section 271C.

Issues: Whether the stay of outstanding tax demand should be extended pending disposal of the assessee's appeal.

Analysis: The appeal remained pending for reasons not attributable to the assessee, while substantial fixed deposits had already been attached by the Revenue. The pending appeals were also directed to be heard expeditiously.

Conclusion: Stay of the outstanding demand was extended for 180 days or until disposal of the appeal, whichever is earlier.

Issues: (i) Whether Notification No. 22/2014-Service Tax validly conferred pan-India jurisdiction on specified Central Excise Officers for service-tax investigations and issuance of show-cause notices; (ii) Whether non-compliance with the departmental pre-consultation circular invalidated the show-cause notices.

Issue (i): Whether Notification No. 22/2014-Service Tax validly conferred pan-India jurisdiction on specified Central Excise Officers for service-tax investigations and issuance of show-cause notices.

Analysis: Section 2(b) of the Central Excise Act, 1944, Rule 3 of the Central Excise Rules, 2002, Rule 3 of the Service Tax Rules, 1994, and the relevant notifications authorised the Board to appoint and invest Central Excise Officers with powers under Chapter V of the Finance Act, 1994. The expression "local limits" did not prohibit assignment of all-India jurisdiction. Notification No. 22/2014-Service Tax was read with the pre-existing Notification No. 38/2001-C.E. (N.T.), which had vested the concerned intelligence officers with pan-India authority. Plurality of empowered officers did not invalidate the notification or offend comity of jurisdiction.

Conclusion: Notification No. 22/2014-Service Tax validly conferred pan-India jurisdiction, and show-cause notices issued by officers outside the taxpayer's local zone were valid. The finding is against the assessee.

Issue (ii): Whether non-compliance with the departmental pre-consultation circular invalidated the show-cause notices.

Analysis: The pre-consultation requirement in the Master Circular was recommendatory and could not prevail over the governing statute. Non-observance of that departmental guidance did not furnish a basis to quash a show-cause notice.

Conclusion: Non-compliance with pre-consultation did not invalidate the show-cause notices. The finding is against the assessee.

Final Conclusion: The notification, investigation, and show-cause process remained legally sustainable; challenges to factual matters arising from orders-in-original must be pursued through the statutory appellate remedy.

Ratio Decidendi: A statutory power to assign officers within "local limits" permits the Board to confer pan-India jurisdiction where the applicable legislative scheme and notifications so provide, and a recommendatory departmental circular cannot override that statutory authority.

Issues: Whether the Revenue's challenge to deletion of the addition of long-term capital gains as unexplained cash credit under Section 68 of the Income-tax Act, 1961 raised any substantial question of law.

Analysis: The shares had been acquired approximately seven years before their sale, were sold through the stock exchange, and the transactions were supported by payment of Securities Transaction Tax. The addition was based only on general information regarding the alleged penny-stock nature of the scrip, without a specific finding linking the assessee or the broker to price manipulation or establishing that the transactions were non-genuine. The concurrent factual findings of the appellate authorities were therefore not shown to be perverse or legally unsustainable.

Conclusion: No substantial question of law arose from the Tribunal's order deleting the addition under Section 68 of the Income-tax Act, 1961.

Issues: Whether reassessment for denying deduction for a port infrastructure facility was valid where the eligibility grounds had been examined in the original scrutiny assessment and the reopening was based on a Revenue audit objection.

Analysis: The relevant enterprise was the Bharathi Dock undertaking owned by the assessee, an Indian-registered company; the foreign shareholding of the assessee did not breach the ownership condition. The record also showed substantial development of the dock through installation of cranes and capital investment, notwithstanding use of certain existing leased assets. These matters, the licence arrangement and the deduction claim had been fully disclosed and examined during the original scrutiny assessment. No new tangible material emerged thereafter. The recorded reasons consequently represented a change of opinion, and reopening merely at the instance of an audit party, without anything further, was impermissible.

Conclusion: The reassessment proceedings were illegal and the notice reopening assessment, order rejecting objections, show-cause notice and draft assessment order were quashed, in favour of the assessee.

Issues: (i) Whether a notice under Section 148 dated and digitally signed on 31 March 2021, but transmitted through the Department's ITBA email system on 1 April 2021, was issued on 1 April 2021; (ii) whether the notice and consequential assessment were required to be dealt with under the reassessment procedure introduced with effect from 1 April 2021.

Issue (i): Whether the notice was issued on 1 April 2021.

Analysis: The date on which the Department's ITBA email system triggered and dispatched the notice is attributable to the Department. Although the notice was dated and digitally signed on 31 March 2021, the system delivery report established that its transmission was triggered only on 1 April 2021. The date of generation or digital signature was therefore distinct from the date of issuance.

Conclusion: The notice was deemed to have been issued on 1 April 2021.

Issue (ii): Whether the notice and consequential assessment were required to comply with the reassessment procedure introduced from 1 April 2021.

Analysis: A notice issued under the unamended Section 148 after 1 April 2021 was required to be treated, in accordance with the substituted reassessment framework and the directions governing such notices, as a show-cause notice under Section 148A(b). The assessment order passed under Sections 147 and 144B without following that procedure could not stand. The Assessing Officer was required to provide the relied-upon information and material, consider the objections, pass an order under Section 148A(d), and thereafter proceed in accordance with law, while preserving the parties' available statutory defences and contentions.

Conclusion: The assessment order and consequential proceedings were quashed, and the notice was to be treated as a show-cause notice under Section 148A(b) for fresh consideration under the substituted reassessment procedure.

Final Conclusion: The reassessment proceedings were reopened for consideration under the applicable post-1 April 2021 procedure, without foreclosing the assessee's statutory defences or the Revenue's legal contentions.

Ratio Decidendi: For a notice generated and digitally signed before 1 April 2021 but transmitted through the Department's ITBA email system on or after that date, the ITBA transmission date is the date of issuance, and the notice must be dealt with under the substituted reassessment procedure.

Issues: (i) Whether addition on alleged bogus purchases could be restricted to 6% of the impugned purchases instead of sustaining 100% disallowance under the reopening assessment; (ii) Whether the Revenue could maintain a further appeal against the Tribunal's order in the connected matter where the Tribunal had dismissed the assessee's appeal and thereby granted relief in favour of the Revenue.

Issue (i): Whether addition on alleged bogus purchases could be restricted to 6% of the impugned purchases instead of sustaining 100% disallowance under the reopening assessment.

Analysis: The dispute arose from purchases treated as non-genuine on the basis of investigation material relating to accommodation entries. The sales were not disputed, and the quantitative and qualitative details were also not disbelieved. The Tribunal proceeded on the footing that, where actual sales stand accepted, complete disallowance of purchases is not justified and only the profit element embedded in such purchases can be brought to tax. In adopting 6%, the Tribunal followed the consistent approach applied in similar cases involving the same entry-provider pattern and the same line of trade, which had already received approval in earlier decisions of the jurisdictional High Court. The estimation was thus treated as a factual and reasoned exercise based on the material on record, and not as giving rise to any substantial question of law.

Conclusion: Restriction of the addition to 6% of the impugned purchases was upheld; the issue was decided against the Revenue and in favour of the assessee.

Issue (ii): Whether the Revenue could maintain a further appeal against the Tribunal's order in the connected matter where the Tribunal had dismissed the assessee's appeal and thereby granted relief in favour of the Revenue.

Analysis: In the connected appeal, the Tribunal had rejected the assessee's challenge, resulting in an order favourable to the Revenue. Since the Revenue was not adversely affected by that order, the requirement of being an aggrieved party was absent. On that basis, the proposed question of law was not taken up for answer.

Conclusion: The Revenue was not entitled to pursue the connected appeal against an order operating in its favour; the issue was decided against the Revenue.

Final Conclusion: The challenge to the Tribunal's estimation of disallowance failed, the earlier line of decisions on taxing only the embedded profit element in such bogus purchase cases was followed, and the connected appeal by the Revenue was declined for want of grievance.

Ratio Decidendi: Where alleged bogus purchases are linked to accommodation entries but the corresponding sales and trading details are not rejected, a reasonable estimate of the profit element rather than 100% disallowance is sustainable, and no further appeal lies at the instance of a party not aggrieved by the order under challenge.

Issues: (i) whether the impugned transactions shown as purchases from M/s Sanmati Trading Co. constituted benami transactions carried out in a fictitious name under Section 2(9)(B) of the Prohibition of Benami Property Transactions Act, 1988; (ii) whether the provisional attachment of the amount lying in the appellants' bank account was valid, including the objection that attachment could not be made in the hands of the beneficial owner and that the burden of proving benami transaction remained solely on the respondents.

Issue (i): whether the impugned transactions shown as purchases from M/s Sanmati Trading Co. constituted benami transactions carried out in a fictitious name under Section 2(9)(B) of the Prohibition of Benami Property Transactions Act, 1988.

Analysis: Section 2(9)(B) covers a transaction or arrangement in respect of property carried out or made in a fictitious name. Non-filing of income-tax returns by itself was treated as insufficient to prove fictitious existence, but the matter was decided on the cumulative effect of surrounding circumstances. The material relied upon included the non-existence of the stated entity at the given address, repeated non-service of summons, failure of physical verification, inconsistency between the GST registration profile of the entity and the alleged supply of clothes and fabrics, inability to trace the alleged banking trail of the supplier, absence of credible supporting documents for supply and delivery, and failure of the appellants to rebut these circumstances with reliable evidence. On that evidentiary foundation, the initial burden stood discharged by the respondents and the appellants failed to displace it.

Conclusion: The transactions were rightly treated as benami transactions in a fictitious name under Section 2(9)(B) of the Prohibition of Benami Property Transactions Act, 1988, against the appellants and in favour of the respondent.

Issue (ii): whether the provisional attachment of the amount lying in the appellants' bank account was valid, including the objection that attachment could not be made in the hands of the beneficial owner and that the burden of proving benami transaction remained solely on the respondents.

Analysis: The attachment challenge was examined in the context of the finding that the alleged purchase payments were part of a fictitious routing arrangement and that the money was effectively returning to the appellants. Once the respondents established the factual basis showing a fictitious transaction, the appellants were required to explain and rebut the material, which they failed to do. The objection that attachment could be made only in the hands of the benamidar was not accepted because the case fell under Section 2(9)(B), where the transaction itself was found to be fictitious, making attachment in the hands of the person orchestrating and benefiting from the fictitious arrangement legally sustainable.

Conclusion: The provisional attachment of the amount in the appellants' bank account was valid, against the appellants and in favour of the respondent.

Final Conclusion: The confirmation of provisional attachment was sustained because the alleged purchase arrangement was proved to be a fictitious-name transaction and the routed funds were lawfully attachable in the hands of the persons benefiting from that arrangement.

Ratio Decidendi: Where a transaction is shown through cumulative objective circumstances to have been carried out in the name of a non-existent or fictitious entity, it falls within Section 2(9)(B) of the Prohibition of Benami Property Transactions Act, 1988, and once the initiating authority discharges the initial burden, the failure of the affected party to rebut the material justifies confirmation of attachment even in the hands of the beneficial participant in the fictitious arrangement.

Issues: (i) Whether the amount received by the appellant before the period of commission of the scheduled crime constituted proceeds of crime; (ii) whether property of equivalent value could be provisionally attached in the absence of receipt or diversion of proceeds of crime; and (iii) whether the Enforcement Directorate could sustain the attachment to recover an amount allegedly due to the transferor.

Issue (i): Whether the amount received by the appellant before the period of commission of the scheduled crime constituted proceeds of crime.

Analysis: The amount of Rs. 10 Crores was transferred to the appellant in 2004, whereas the diversion of home-buyers' funds constituting the alleged crime occurred during 2006-07 to 2014-15. The payment was made in the course of a proposed sale of shops and was maintained as a credit balance with the appellant. On the material facts, the amount was not shown to have originated from or been diverted out of the proceeds generated during the crime period.

Conclusion: The amount received by the appellant was not proceeds of crime.

Issue (ii): Whether property of equivalent value could be provisionally attached in the absence of receipt or diversion of proceeds of crime.

Analysis: Attachment of property of equivalent value presupposes the existence of proceeds of crime and their receipt or diversion by the person whose property is attached. Since the appellant had neither received nor diverted proceeds of crime, the statutory basis for attaching its fixed deposit for an equivalent value was absent.

Conclusion: The equivalent-value attachment of the appellant's fixed deposit was unsustainable.

Issue (iii): Whether the Enforcement Directorate could sustain the attachment to recover an amount allegedly due to the transferor.

Analysis: The failure to complete the shop transaction and the alleged non-refund of the amount could give rise to a civil recovery claim between the appellant and the transferor. Such a claim did not convert the amount into proceeds of crime and could not authorise the Enforcement Directorate to act as a recovery agent by attaching the amount with accrued interest.

Conclusion: The attachment could not be sustained as a recovery measure for the transferor.

Final Conclusion: The confirmation of the provisional attachment was set aside, without preventing the transferor's new management from pursuing recovery of the Rs. 10 Crores in accordance with law.

Ratio Decidendi: Attachment under the Prevention of Money Laundering Act requires a demonstrated nexus between the attached property and proceeds of crime, including their receipt or diversion; property cannot be attached merely to recover a pre-existing civil debt.

Issues: Whether the assessment order was liable to be set aside and the matter remanded on the ground that Circular No. 13/2021 dated 30.06.2021 issued under section 194Q of the Income-tax Act, 1961 was not considered.

Analysis: The petition challenged the assessment order passed under section 143(3) read with section 144B and the consequential penalty notice, contending that the assessing authority had not adverted to Circular No. 13/2021 issued under section 194Q. The circular laid down guidelines on the scope and working of section 194Q, including threshold computation and related clarifications, and was relevant to the controversy raised in the assessment. Since the circular was not considered while passing the impugned order, the order could not be sustained and the matter required reconsideration in the light of the circular and in accordance with law.

Conclusion: The assessment order was set aside and the matter was remitted for fresh consideration, resulting in relief to the assessee.

Issues: (i) Whether the assessee's registration under Section 12AB was liable to be treated as that of a religious entity or as a religious cum charitable entity; (ii) Whether approval under Section 80G(5) could be denied on the basis of one object clause alleging religious character despite the assessee's actual activities being educational and medical in nature and available to the public at large.

Issue (i): Whether the assessee's registration under Section 12AB was liable to be treated as that of a religious entity or as a religious cum charitable entity.

Analysis: The registration order itself described the nature of activities as religious cum charitable, but the annexure classified the assessee as a religious entity. The financial statements, objects, and activity records showed income from hospital, medical college, and allied welfare operations, with expenditure directed toward healthcare, education, research, staff, and related institutional functions. The material on record showed that services were rendered without restriction to any religion or community and that financial concessions were extended on economic considerations. No factual material established that the assessee was carrying on religious activities as its operative activity base.

Conclusion: The assessee was entitled to registration as a religious cum charitable entity and not merely as a religious entity; this issue was decided in favour of the assessee.

Issue (ii): Whether approval under Section 80G(5) could be denied on the basis of one object clause alleging religious character despite the assessee's actual activities being educational and medical in nature and available to the public at large.

Analysis: The denial of approval rested only on an object clause referring to church yards, burial grounds, and related works, and on Section 80G(5)(iii) with Explanation 3. No factual finding was recorded that the assessee had actually carried out religious activities during the relevant period. The accounts and activity profile instead reflected medical, educational, and research functions for the general public. Earlier adjudication on the same assessee, based on substantially identical objects and activities, had recognized that medical care, education, and concessional treatment were available irrespective of caste, creed, race, language, or religion, and that the institution was charitable in substance. There being no change in facts, the same view was applicable.

Conclusion: Approval under Section 80G(5) could not be denied merely on selective reliance upon a general object clause when the assessee's actual activities were charitable and not shown to be religious in substance; this issue was decided in favour of the assessee.

Final Conclusion: The assessee's institutional character was found to be charitable in operation notwithstanding its Christian background, and its public-facing medical and educational activities did not attract disqualification applicable to institutions established for the benefit of a particular religious community or for substantially religious purposes. The registration category was required to be corrected accordingly and the approval claim was required to be granted.

Ratio Decidendi: Where the actual activities of an institution are educational, medical, and welfare-oriented for the benefit of the public without religious discrimination, approval and registration cannot be denied merely by selectively reading one object clause suggestive of religious association in the absence of factual proof that the whole or substantially the whole of its purpose is religious.

Issues: Whether the difference between the aggregate future rent receivables and the amount paid by banks/NBFCs under a non-recourse sale or assignment of receivables could be treated as interest or discounting charges attracting tax deduction at source under Section 194A of the Income-tax Act, 1961, thereby justifying demands under Sections 201(1) and 201(1A) of the Income-tax Act, 1961.

Analysis: The assessee's business model was found to be one of dealing in residuary interest in rented assets, under which it entered into master rental arrangements with customers and separately assigned or sold the right to receive future rentals to financiers under sale of receivables agreements on a non-recourse basis. The legal framework applied was Section 2(28A) of the Income-tax Act, 1961, which defines interest as an amount payable in respect of moneys borrowed or debt incurred, along with Section 36(1)(iii) of the Income-tax Act, 1961 and Section 194A of the Income-tax Act, 1961, both of which proceed on the existence of borrowing or debt and an interest payment arising therefrom.

Analysis: On the terms of the transaction, the Tribunal found that the financiers purchased the receivables and had recourse only against the renter or customer in case of default, and not against the assessee. The statements of the financiers also showed that they treated the renters as borrowers and the assessee's transaction as purchase of receivables. Since the assessee had no obligation to repay the amount received from the financiers, the receipt was held to be consideration for assignment or sale of receivables and not borrowed money. The shortfall between future rentals and the negotiated upfront consideration was therefore only a consequence of valuation and time value of money in a sale transaction, and not interest. The accounting treatment adopted by the financiers was held not to determine the legal character of the assessee's transaction. The authorities were therefore found to have wrongly applied the concept of discounting charges as interest to a non-recourse assignment of receivables.

Conclusion: The difference between future rental receivables and the amount received by the assessee from financiers under non-recourse assignment or sale of receivables is not interest within the meaning of Section 2(28A) of the Income-tax Act, 1961; Section 194A of the Income-tax Act, 1961 is not attracted; and the demands raised under Sections 201(1) and 201(1A) of the Income-tax Act, 1961 are unsustainable. This issue is decided in favour of the assessee.

Issues: Whether the appeal before the Commissioner (Appeals) was rightly rejected as time-barred when the department lacked proof of proper service of the Order-in-Original and the assessee asserted receipt only on 11.03.2024.

Analysis: The limitation question was examined with reference to Section 85 of the Finance Act, 1994 and the mode of service contemplated through Section 83 of the Finance Act, 1994 read with Section 37C of the Central Excise Act, 1944. The record showed inconsistency in the appellate authority's findings regarding dispatch and return of the registered post containing the Order-in-Original. The material on record did not establish proof of actual delivery to the assessee. In the absence of proof of acknowledgment or proper receipt, mere dispatch could not be treated as valid service. On that basis, the date on which a copy of the order was admittedly provided to the assessee, namely 11.03.2024, was treated as the relevant date of receipt for computing limitation. Since the appeal was filed on 16.05.2024, it was beyond the initial two-month period but within the further condonable period of one month.

Conclusion: The appeal was within limitation and the rejection on the ground of limitation was unsustainable; the issue was decided in favour of the assessee, the impugned order was set aside, and the matter was remanded to the Commissioner (Appeals) for decision on merits.

Issues: Whether service tax paid on dealer commissions for sales promotion activities could be treated as CENVAT credit eligible input service under Rule 2(l) of the CENVAT Credit Rules, 2004, and whether the demand confirmed under Rule 14 of the CENVAT Credit Rules, 2004 read with Section 11A of the Central Excise Act, 1944 was sustainable.

Analysis: The dealers were engaged under the agreements specifically to promote sale of the goods manufactured by the appellant, and the invoices reflected service tax on such sales promotion activity. The inclusive part of Rule 2(l) expressly covers sales promotion as an input service. The Tribunal also noted that the facts were identical to the earlier decision relied upon, where credit on sales promotion services had been allowed.

Conclusion: The service tax paid on the dealer services qualified as input service, and denial of CENVAT credit was unsustainable. The demand confirmed below was set aside, and the appeal succeeded in favour of the assessee.

Issues: Whether the auction purchaser was entitled to registration of the sale certificate free from the State tax encumbrance, and whether the attachment order and revenue entry created for sales tax dues could override the secured creditor's prior claim.

Analysis: The security interest of the secured creditor had been registered with CERSAI long before the State attachment, while the State charge was neither shown to be registered nor supported by compliance with the procedural requirements governing attachment and proclamation under the revenue recovery framework. The amended Section 37 of the Maharashtra Value Added Tax Act, 2002 did not assist the State, as an identical contention had already been rejected, and the law remained that a duly registered secured creditor's statutory priority under the SARFAESI regime prevails over State revenue claims, including tax dues.

Conclusion: The auction purchaser's claim was upheld. The attachment order and encumbrance were liable to be quashed, and registration of the sale certificate was directed without insisting on the State's no-objection.