Issues: (i) Whether an importer using forged or manipulated transferable duty-credit scrips through an authorised customs-clearance agent can claim protection as a bona fide purchaser; (ii) Whether non-production of original scrips and allied documents, and denial of cross-examination of Customs officers, vitiate the proceedings for breach of natural justice; (iii) Whether penalties under Sections 112 and 114A of the Customs Act, 1962 are sustainable where the importer claims lack of actual knowledge of the manipulation.

Issue (i): Whether an importer using forged or manipulated transferable duty-credit scrips through an authorised customs-clearance agent can claim protection as a bona fide purchaser.

Analysis: An authorised agent's acts within the scope of authority are attributable to the importer under Sections 182, 186 and 226 of the Indian Contract Act, 1872 and Section 147 of the Customs Act, 1962. The importer authorised the agent to undertake customs clearance and utilise scrips, obtained the resulting duty benefit, and could not disclaim the consequences of that agency.

Analysis: The equitable principle underlying Section 41 of the Transfer of Property Act, 1882 requires good faith and reasonable care. The excess value reflected in manipulated EDI records was never part of the entitlement issued by the DGFT and could not be transferred under the principle of nemo dat quod non habet. The importer neither verified the scrips, their source, validity or available balance, nor questioned material irregularities in the clearance arrangements. Caveat emptor required such due diligence.

Conclusion: The importer cannot claim bona fide purchaser protection or avoid liability for duty benefits derived from manipulated scrips. This issue is decided against the assessee.

Issue (ii): Whether non-production of original scrips and allied documents, and denial of cross-examination of Customs officers, vitiate the proceedings for breach of natural justice.

Analysis: The evidentiary basis comprised DGFT entitlement data, customs registration records, EDI transaction trails, electronic records and statements recorded under Section 108 of the Customs Act, 1962. Under Section 119 of the Bharatiya Sakshya Adhiniyam, 2023, an adverse inference from non-production is discretionary and does not arise where the relevant facts are independently established.

Analysis: The importer had never possessed or independently verified the disputed original scrips and did not establish any actual prejudice from their absence. The denial of cross-examination likewise did not invalidate the proceedings because no material fact or resulting prejudice was identified.

Conclusion: The proceedings are not vitiated by non-production of original documents or denial of cross-examination. This issue is decided against the assessee.

Issue (iii): Whether penalties under Sections 112 and 114A of the Customs Act, 1962 are sustainable where the importer claims lack of actual knowledge of the manipulation.

Analysis: Section 114A applies where duty is short-levied through fraud, wilful misstatement or suppression intended to evade duty. The importer filed Bills of Entry relying on scrips without verifying their existence, validity or credit balance, and directly benefited from the manipulated credits. Personal execution of the electronic manipulation was not necessary for the statutory penalty.

Analysis: The proviso to Section 114A excludes a separate penalty under Section 112 where penalty is imposed under Section 114A.

Conclusion: Penalty under Section 114A is sustained, while the separate penalty under Section 112 is set aside. This issue is partly in favour of the assessee.

Final Conclusion: The findings apply equally to the connected writ matters arising from the same investigation, and the customs-duty consequences founded on the manipulated duty-credit scrips remain enforceable subject to removal of the separate Section 112 penalty.

Ratio Decidendi: An importer that authorises an agent to use transferable duty-credit scrips and obtains the resulting benefit remains responsible for manipulated or excess credits where it failed to exercise reasonable diligence; absence of original instruments does not invalidate proceedings supported by independent reliable evidence and absent demonstrable prejudice.

Issues: Whether service tax paid on a contractual advance, where no service was rendered and the entire advance was recovered upon termination of the contract, was refundable without the limitation under Section 11B.

Analysis: The contractual advance was received against a project that was terminated before commencement, and no service was provided or consideration adjusted against contractual performance. The entire advance was recovered through encashment of the bank guarantee, while the incidence of the tax payment remained with the assessee. A payment made where no taxable service was rendered does not retain the character of service tax legally payable; it is a deposit with the Revenue. Consequently, the refund limitation applicable to duty under Section 11B did not govern the claim. In any event, the entitlement to refund arose upon termination of the contract and recovery of the advance.

Conclusion: The refund claim was not time-barred under Section 11B, and the assessee was entitled to refund with consequential relief.

Issues: Whether production-of-goods services undertaken on job work and exempted under Notification No. 8/2005-S.T., where the processed goods are returned to the client for manufacture of duty-paid final products, are exempted services attracting reversal of CENVAT credit under Rule 6 of the CENVAT Credit Rules, 2004.

Analysis: The job-work exemption applies where goods produced from materials supplied by the client are returned for use in manufacture of final products on which appropriate excise duty is payable. The client's final products were admittedly cleared on payment of duty. CENVAT credit eligibility for inputs and input services used in such job work is preserved under Rule 3 of the CENVAT Credit Rules, 2004; consequently, the restriction applicable to exempted services under Rule 6 is inapplicable.

Conclusion: The job-work services were not to be treated as exempted services for the purpose of Rule 6, and the CENVAT credit was admissible.

Issues: Whether the reassessment notice issued for Assessment Year 2015-16 after expiry of six years from the end of the relevant assessment year was barred by limitation.

Analysis: The first proviso to Section 149(1)(b) preserves the limitation applicable under the pre-amendment regime for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, the outer six-year period expired on 31 March 2022. The extended limitation under the amended regime could not operate retrospectively to revive a notice that was already time-barred, and the exclusion provisions relating to proceedings under Section 148A did not extend the restriction imposed by the first proviso.

Conclusion: The notice issued under Section 148 on 7 April 2022 was barred by limitation; the consequential reassessment order was vitiated and quashed in favour of the assessee.

Issues: (i) Whether entitlement to refund of accumulated input tax credit under the inverted-duty structure can be determined in advance-ruling jurisdiction; (ii) Whether the first proviso to Section 98(2) bars admission of the classification and rate questions; (iii) Whether Rubberised Cork Sheets/Agglomerated Cork Sheets are classifiable under Tariff Item 45041010; (iv) Whether those goods are covered by Serial No. 310 of Schedule I to Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 and taxable at 5%; (v) Whether notification benefit can be denied because the goods are not natural cork.

Issue (i): Whether entitlement to refund of accumulated input tax credit under the inverted-duty structure can be determined in advance-ruling jurisdiction.

Analysis: The matters enumerated in Section 97(2) are exhaustive and do not include determination of entitlement to refund of accumulated input tax credit under clause (ii) of the first proviso to Section 54(3).

Conclusion: The refund-eligibility question was not admitted as outside advance-ruling jurisdiction, against the assessee.

Issue (ii): Whether the first proviso to Section 98(2) bars admission of the classification and rate questions.

Analysis: No pending or concluded proceeding concerning the classification or rate question was established. A verbal doubt during refund scrutiny did not constitute a proceeding for the purpose of the statutory bar.

Conclusion: The statutory bar was not attracted and the classification and rate questions were admitted, in favour of the assessee.

Issue (iii): Whether Rubberised Cork Sheets/Agglomerated Cork Sheets are classifiable under Tariff Item 45041010.

Analysis: Rule 1 requires classification according to the heading terms and relevant notes. Heading 4504 expressly covers agglomerated cork with or without a binding substance, without prescribing any limit on the quantity or type of binder. The manufacturing process showed that cork granules were agglomerated, while polymer and other materials formed the binder system; Chapter 45 contains no exclusion for cork agglomerated with rubber.

Conclusion: Rubberised Cork Sheets and Agglomerated Cork Sheets are classifiable under Tariff Item 45041010, in favour of the assessee.

Issue (iv): Whether those goods are covered by Serial No. 310 of Schedule I to Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 and taxable at 5%.

Analysis: The notification adopts the Customs Tariff classification rules. Serial No. 310 covers all goods under heading 4504, including agglomerated cork with or without a binding substance, without limiting the entry to a particular tariff item or imposing a condition. The entry provides central tax at 2.5%, with corresponding State tax at 2.5%.

Conclusion: The goods are covered by Serial No. 310 and attract GST at 5% for supplies made on or after 22.09.2025, in favour of the assessee.

Issue (v): Whether notification benefit can be denied because the goods are not natural cork.

Analysis: Chapter 45 separately identifies natural cork under headings 4501 to 4503 and agglomerated cork under heading 4504. The notification likewise separately covers natural cork and agglomerated cork. The classification turns on the tariff description and identity of the finished goods, not on the natural state or botanical origin of the cork granules.

Conclusion: The notification benefit cannot be denied because the goods are not natural cork or because cork originates from the bark of a cork oak tree, in favour of the assessee.

Final Conclusion: Classification under heading 4504 carries the specified concessional rate, while refund entitlement remains outside the scope of the advance ruling.

Ratio Decidendi: Where a tariff heading expressly covers agglomerated cork with or without a binding substance, goods satisfying that description cannot be excluded based on binder content or lack of natural-cork status.

Issues: Whether excisable goods stock-transferred to sister units for captive consumption were correctly valued under Rule 8 rather than Rule 4.

Analysis: Rule 8 governs valuation of goods captively consumed by sister units in further manufacture. The prescribed cost of production is to be determined under CAS-4 in accordance with Circular No. 692/8/2003-CX dated 13.02.2003, which is binding on the Revenue. The Rule 4 valuation principle applicable to transfers not involving captive consumption was inapplicable.

Conclusion: Duty was correctly paid under Rule 8 on the CAS-4 basis; Rule 4 did not apply and no differential duty was payable.

Issues: Whether an assessment made under section 143(3) in the name of a partnership firm that had ceased to exist upon conversion into a private limited company is valid.

Analysis: An assessment under Section 143(3) of the Income-tax Act, 1961 must be made upon an existing assessee. The partnership firm had converted into a private limited company with effect from 19.01.2020, and this change was communicated to the Assessing Officer before the assessment order dated 29.09.2022. The firm was consequently non-existent on the date of assessment; settled judicial principles prohibit an assessment against such an entity.

Conclusion: The assessment order passed in the name of the non-existent partnership firm was void and was quashed.

Issues: Whether Indian Refractory Mortar exported by the appellants was classifiable under CTH 3816 0000 as refractory mortar or under CTH 2610 as chromium ores and concentrates.

Analysis: Applying the settled classification of identical goods, the mixture of chromite with magnesite and bentonite had a chemical composition distinct from chromite, was intended for refractory applications, and was not subjected to processes normal to the metallurgical extraction of chromium. Under Rule 1 of the General Rules for Interpretation, read with Chapter Note 2 to Chapter 26 and the HSN Explanatory Notes, it fell outside Chapter 26 and answered the description of refractory mortar under Heading 3816.

Conclusion: The goods are classifiable under CTH 3816 0000 and not under CTH 2610; no export duty or penalty is payable or imposable.

Ratio Decidendi: A mineral mixture not processed for, or actually used in, metallurgical extraction falls outside Chapter 26 under its chapter note and is classifiable under the heading describing its refractory function.

Issues: Whether a one-day delay in remitting employees' EPF/ESI contributions, caused by unavailability of the EPFO portal during Aadhaar seeding and payment-gateway glitches, disentitled the assessee to deduction under Section 36(1)(va) of the Income-tax Act, 1961.

Analysis: Timely credit of employees' contributions to the prescribed funds is ordinarily a condition for deduction under Section 36(1)(va). The record showed timely filing of the monthly electronic return and scheduling of payment, while the EPFO portal was unavailable during Aadhaar seeding and the payment was debited from the assessee's account on the following morning. The contemporaneous EPFO relief circular corroborated the technical disruption. The delay was accidental, bona fide, and exclusively attributable to external technical causes beyond the assessee's control.

Conclusion: The remittance was to be treated as made within the prescribed due date, and deduction under Section 36(1)(va) was allowable in respect of the employees' contributions.

Issues: Whether approval under section 80G may be denied to a religious or religious-cum-charitable institution without determining whether its religious expenditure exceeds five per cent of total income.

Analysis: Explanation 3 to section 80G excludes a purpose that is wholly or substantially wholly religious from the meaning of charitable purpose. Section 80G(5B), by its non obstante formulation, creates a deeming fiction: an institution or fund incurring religious expenditure not exceeding five per cent of its total income during the relevant previous year is treated as an institution to which section 80G applies. The five per cent test cannot be disregarded merely because the institution has religious or religious-cum-charitable objects. The record did not contain a verified computation establishing that the assessee's religious expenditure exceeded the prescribed threshold.

Conclusion: Approval under section 80G cannot be denied on the stated ground without determining the actual religious expenditure against the five per cent threshold; approval must follow if that threshold and the remaining statutory conditions are satisfied.

Issues: Whether a single composite show cause notice and composite assessment order covering multiple tax periods or financial years are sustainable under the statutory assessment scheme.

Analysis: Sections 73(3) and 74(3) contemplate proceedings referable to the relevant tax period. A combined notice and order for multiple years impairs the registered person's statutory rights, including the benefit available under Section 128 and the ability to pursue an effective appeal against an assessment for an individual tax period. The settled interpretation applicable to the matter does not permit a single notice or composite assessment order for more than one year where the due date for filing the annual return has been reached.

Conclusion: The composite notice and assessment order covering the tax periods 2021-22 to 2024-25 were unsustainable and were set aside, in favour of the assessee.

Issues: Whether an order under Section 74 founded on a show-cause notice uploaded only on the GST portal after cancellation of the taxpayer's registration violates principles of natural justice.

Analysis: After cancellation of registration, the taxpayer was not obliged to monitor the GST portal. Service of a show-cause notice solely through that portal was therefore insufficient, and the notice was required to be served through an alternative mode enabling an effective opportunity of response.

Conclusion: The order passed under Section 74 without valid service of notice and opportunity of hearing was vitiated for breach of principles of natural justice; the Department may issue a proper notice and proceed in accordance with law.

Issues: (i) Whether the requirement under Rule 164(6) for filing an application under the GST amnesty scheme is mandatory; (ii) Whether the ex parte original order should be set aside for fresh consideration where the entire tax demand had been discharged.

Issue (i): Whether the requirement under Rule 164(6) for filing an application under the GST amnesty scheme is mandatory.

Analysis: Section 128A permits waiver in specified circumstances subject to prescribed conditions. The comma preceding the qualifying phrase does not render those conditions directory. Rule 164 governs a time-bound scheme involving deemed approval, with time limits running from or closely linked to the waiver application. The prescribed time limit is an essential, and not merely procedural, requirement.

Conclusion: The condition under Rule 164(6) is mandatory and not directory, against the assessee.

Issue (ii): Whether the ex parte original order should be set aside for fresh consideration where the entire tax demand had been discharged.

Analysis: The full tax demand under the ex parte original order had been paid, thereby safeguarding revenue interests. In these circumstances, fairness required that the assessee receive a reasonable opportunity before a fresh determination.

Conclusion: The ex parte original order is set aside and the matter requires fresh consideration after affording reasonable opportunity to the assessee, in favour of the assessee.

Final Conclusion: The mandatory character of the amnesty-application time limit remains unaffected, but the tax demand must be freshly determined after hearing the assessee.

Ratio Decidendi: In a time-bound amnesty scheme, a prescribed deadline for filing the waiver application is an essential mandatory condition and cannot be treated as directory.

Issues: Whether an ex parte GST adjudication could stand where the assessee lacked effective notice of the show-cause and hearing proceedings because communications were sent only to the e-mail address of its erstwhile auditor.

Analysis: The reasons for non-response were found plausible and bona fide. Service on the registered e-mail credentials of an erstwhile auditor with whom the assessee was no longer in contact did not afford the assessee an effective opportunity to respond to the show-cause notice or participate in the adjudication. The requirements of a fair hearing therefore warranted fresh consideration after permitting a response and supporting transaction documents.

Conclusion: The ex parte adjudication was unsustainable for want of an effective opportunity of hearing, and the matter was required to be reconsidered afresh by the adjudicating authority.

Issues: Whether the notice for reassessment issued for Assessment Year 2015-16 on 31.07.2022 was barred by limitation.

Analysis: The first proviso to Section 149(1) preserves the limitation applicable under the pre-amendment regime for assessment years commencing on or before 01.04.2021. For Assessment Year 2015-16, the six-year period under the unamended provision expired on 31.03.2022. The Revenue's concession recorded in binding decisions established that notices for this assessment year issued on or after 01.04.2021 were outside the period protected by TOLA. The legal fiction arising from the directions concerning reassessment notices could not extend the expired statutory limitation for an assessment year to which TOLA did not apply.

Conclusion: The notice issued under Section 148 on 31.07.2022 was time-barred; the consequential reassessment proceedings and reassessment order were invalid and quashed.

Issues: (i) Whether the support-services payment to associated enterprises could be benchmarked at nil under the Other Method; (ii) Whether the selected comparables were appropriate for determining the IPS-segment margin under TNMM; (iii) Whether the selected comparables were appropriate for determining the EEC-segment margin under TNMM; (iv) Whether specified write-backs, miscellaneous income, foreign-exchange gain and export incentives were operating items for computing the assessee's PLI; (v) Whether a COVID-period economic adjustment was warranted in benchmarking the IPS and EEC segments; (vi) Whether interest could be imputed on overdue receivables from associated enterprises where the assessee was debt-free.

Issue (i): Whether the support-services payment to associated enterprises could be benchmarked at nil under the Other Method.

Analysis: Additional evidence substantiating the benefit from the support services was admitted, consistently with the approach in the assessee's earlier years. The determination requires verification of the benefit derived from the services and fresh benchmarking under TNMM rather than a nil valuation without such verification.

Conclusion: In favour of the assessee: the support-services adjustment is remitted to the AO/TPO for fresh verification and determination under TNMM.

Issue (ii): Whether the selected comparables were appropriate for determining the IPS-segment margin under TNMM.

Analysis: Companies manufacturing kitchen appliances, diesel-generator sets or diverse consumer electrical products were not functionally comparable to the assessee's manufacture of process-control and temperature-control systems. Further, an entity having manufacturing and trading segments without segmental results could not be accepted as a whole-entity comparable. Consistency also supported exclusion of a power-distribution-solutions company already excluded in an earlier year.

Conclusion: Partly in favour of the assessee: Penguin Electronics Ltd. and Powerica Ltd. remain excluded from inclusion, while Novateur Electrical and Digital Systems Pvt. Ltd., Havells India Ltd., Aluminium Industries Ltd. and Tricolite Electrical Industries Ltd. are excluded from the final comparable set.

Issue (iii): Whether the selected comparables were appropriate for determining the EEC-segment margin under TNMM.

Analysis: The three proposed companies directed to be considered by the DRP require verification through a fresh search matrix and inclusion if they appear therein. Entities engaged in IT-enabled services, accounting, insurance, banking, data processing, or advertising and marketing solutions were functionally dissimilar to engineering-estimation services.

Conclusion: In favour of the assessee: the TPO must freshly verify the three proposed companies for inclusion, and Sundaram Business Services Ltd. and Concept Public Relations India Ltd. are excluded as comparables.

Issue (iv): Whether specified write-backs, miscellaneous income, foreign-exchange gain and export incentives were operating items for computing the assessee's PLI.

Analysis: The contract-loss reversals and provisions written back corresponded to operating expenditure recognised in earlier years, while the miscellaneous income, foreign-exchange gain and export incentives were connected with business operations. The same categories had been treated as operating in the assessee's earlier year.

Conclusion: In favour of the assessee: the specified receipts and write-backs must be treated as operating income in computing the PLI.

Issue (v): Whether a COVID-period economic adjustment was warranted in benchmarking the IPS and EEC segments.

Analysis: Although the COVID disruption affected all companies, its impact differed across entities. Comparing the assessee's recession-year result with a weighted multi-year margin of comparables that included normal years was inequitable.

Conclusion: Partly in favour of the assessee: the current-year margin of the final comparable set must be compared with the assessee's current-year margin.

Issue (vi): Whether interest could be imputed on overdue receivables from associated enterprises where the assessee was debt-free.

Analysis: The audited financial statements established that the assessee had no borrowings; the recorded long-term liability represented an Ind AS lease liability rather than interest-bearing debt. In those circumstances, imputation of interest on outstanding associated-enterprise receivables was unwarranted.

Conclusion: In favour of the assessee: the transfer-pricing adjustment for interest on overdue receivables is deleted.

Final Conclusion: The transfer-pricing computation requires fresh or consequential recomputation after verification of support-service evidence, reconsideration of the identified comparable sets, treatment of the specified operating items, application of current-year comparable margins, and deletion of the receivables-interest adjustment.

Issues: (i) Whether the entire alleged suppressed turnover can be assessed as business income, or only its embedded profit; (ii) Whether the disallowance under section 40A(3) could be sustained without payment-wise and person-wise verification.

Issue (i): Whether the entire alleged suppressed turnover can be assessed as business income, or only its embedded profit.

Analysis: The alleged receipts arose from sales of by-products generated in the assessee's disclosed business, and the purchases and source of the goods were not disputed. The Revenue's case was one of under-recording of sale consideration and margins, rather than an independent undisclosed business or unexplained investment in goods. Suppressed turnover includes the cost attributable to the goods and cannot be equated with profit merely because it was not recorded in the books. The assessee's historical net-profit rate of about 1.5% provided the objective basis for reasonable estimation. A moderately higher rate was justified because the unrecorded component represented incremental realisation for which common business expenditure was already absorbed, but no material supported a substantially higher margin.

Conclusion: Only the embedded profit in the suppressed turnover was taxable. The addition was restricted to 2% of Rs. 5,01,11,790, being Rs. 10,02,236, and the balance addition was deleted, in favour of the assessee.

Issue (ii): Whether the disallowance under section 40A(3) could be sustained without payment-wise and person-wise verification.

Analysis: The statutory threshold applies to a payment, or aggregate payments, made to the same person on a single day, not to the aggregate annual debit under a ledger head. The supporting material asserted that the underlying payments were made to different persons or on different dates and were individually below the prescribed limit. Claims for applicable statutory exceptions also required verification from vouchers and payment details.

Conclusion: The disallowance was set aside for limited verification of payment-wise and person-wise details and applicable statutory exceptions. No disallowance may be made solely from aggregate ledger figures where the prescribed same-person, same-day threshold is not exceeded.

Final Conclusion: Taxability of the alleged unrecorded business receipts is confined to a reasonably estimated profit component, while the cash-payment disallowance requires a focused factual examination of the underlying transactions.

Ratio Decidendi: Where alleged suppressed sales arise from the disclosed business and no independent unexplained investment in the corresponding goods is established, only the reasonably estimated profit embedded in the turnover, and not the gross turnover itself, is taxable.

Issues: (i) Whether the material established a prima facie case of the appellant's involvement in money laundering and justified attachment of his properties; (ii) Whether the asserted loan source, absence of initial naming in the FIR or ECIR, absence of a direct money trail, and reliance on a co-accused's statement invalidated the attachment; (iii) Whether properties asserted to have been acquired before the criminal activity could be attached as the value of proceeds of crime.

Issue (i): Whether the material established a prima facie case of the appellant's involvement in money laundering and justified attachment of his properties.

Analysis: The electronic communications, cash-delivery arrangements, statements recorded under the statute, foreign-currency recovery, overseas bank withdrawal, Dubai entity documents, and investment-related communications cumulatively showed active receipt, handling, layering and concealment of proceeds of crime. At the attachment stage, a prima facie nexus with money laundering was sufficient; final determination of criminal liability was reserved for trial.

Conclusion: A prima facie case of involvement in money laundering and a sufficient nexus for attachment were established, against the appellant.

Issue (ii): Whether the asserted loan source, absence of initial naming in the FIR or ECIR, absence of a direct money trail, and reliance on a co-accused's statement invalidated the attachment.

Analysis: The appellant produced no material substantiating the claimed loan despite the reverse burden of proof. His later inclusion in the ECIR did not invalidate the proceedings because the investigation yielded material connecting him with the laundering activities. The case was supported not merely by a co-accused's statement but also by independent electronic, documentary and circumstantial material.

Conclusion: The asserted deficiencies did not invalidate the attachment, against the appellant.

Issue (iii): Whether properties asserted to have been acquired before the criminal activity could be attached as the value of proceeds of crime.

Analysis: The statutory definition of proceeds of crime includes the value of such property. Where the directly derived proceeds are unavailable, untraceable, laundered or held outside India, property of equivalent value may be proceeded against. The timing of acquisition of the attached property did not preclude such attachment.

Conclusion: Property of equivalent value could be attached even if acquired before the criminal activity, where the proceeds of crime were unavailable, against the appellant.

Final Conclusion: The statutory requirements for confirming attachment were satisfied by the prima facie material linking the appellant to laundering activities and by the availability of equivalent-value attachment where direct proceeds were untraceable.

Ratio Decidendi: Where proceeds of crime are unavailable, untraceable or held outside India, the Prevention of Money Laundering Act permits attachment of property of equivalent value, including property acquired before the criminal activity, upon a prima facie showing of involvement in money laundering.