Issues: (i) Whether the final assessment order passed after DRP directions was barred by limitation; (ii) Whether the MLI or its underlying spirit could be invoked to determine PE for assessment year 2020-21; and (iii) Whether the alleged PE and the 30% profit attribution could be sustained on the existing record.

Issue (i): Whether the final assessment order passed after DRP directions was barred by limitation.

Analysis: The retrospective amendment clarified that the limitation under Section 153 governs the passing of the draft assessment order, whereas the final assessment order following DRP directions is governed by Section 144C.

Conclusion: The final assessment order was not time-barred. Against the assessee.

Issue (ii): Whether the MLI or its underlying spirit could be invoked to determine PE for assessment year 2020-21.

Analysis: The relevant MLI provisions were admittedly inapplicable to the assessment year. The existence of a PE must therefore be determined strictly under Article 5 of the India-United Kingdom Double Taxation Avoidance Agreement applicable for that year.

Conclusion: Neither the MLI nor its underlying spirit can be invoked to determine PE for the relevant year. In favour of the assessee.

Issue (iii): Whether the alleged PE and the 30% profit attribution could be sustained on the existing record.

Analysis: Determination of a dependent-agent PE requires examination of the actual contractual arrangements and conduct, including control over pricing, credit risk, contractual obligations, performance responsibility, and the Indian entity's role in soliciting, negotiating, securing and processing orders. Fixed-place and service PE require separate satisfaction of their respective treaty conditions; the Revenue bears the burden of establishing a PE. Acceptance of an earlier assessment concerning another group entity does not create an estoppel for the relevant year. If a PE is found, profit attribution must follow a functions, assets and risks analysis. Arm's-length remuneration does not determine PE existence, but may eliminate further attribution where it fully captures the relevant functions and risks; ad hoc attribution is impermissible.

Conclusion: The PE issue and related profit attribution were remitted for fresh treaty-compliant determination; no final finding on PE or attributable profits was made. In favour of the assessee to the extent of remand.

Final Conclusion: The limitation challenge fails, while the PE inquiry and any profit attribution must be redetermined independently under the applicable treaty, without reliance on the MLI or an ad hoc percentage of receipts.

Ratio Decidendi: PE existence and resultant profit attribution must be determined independently for each year under the applicable treaty on the actual functions, assets, risks and conduct of the parties, and cannot rest on inapplicable MLI principles, prior group assessments or ad hoc attribution.

Issues: (i) Whether donations forming part of mandatory corporate social responsibility expenditure are eligible for deduction under Section 80G of the Income-tax Act, 1961 despite their non-deductibility under Section 37(1) of that Act. (ii) Whether the assessment order allowing that deduction was erroneous and prejudicial to the interests of the Revenue so as to permit revision under Section 263 of the Income-tax Act, 1961.

Issue (i): Whether donations forming part of mandatory corporate social responsibility expenditure are eligible for deduction under Section 80G of the Income-tax Act, 1961 despite their non-deductibility under Section 37(1) of that Act.

Analysis: Explanation 2 to Section 37(1) excludes mandatory corporate social responsibility expenditure under Section 135 of the Companies Act, 2013 from business-expense deduction. That exclusion operates only in computing business income and does not bar an independent statutory deduction under Chapter VI-A where the payment otherwise qualifies as a donation under Section 80G.

Conclusion: Donations forming part of mandatory corporate social responsibility expenditure were eligible for deduction under Section 80G, in favour of the assessee.

Issue (ii): Whether the assessment order allowing that deduction was erroneous and prejudicial to the interests of the Revenue so as to permit revision under Section 263 of the Income-tax Act, 1961.

Analysis: Revisionary jurisdiction requires both an erroneous assessment order and prejudice to the interests of the Revenue. The assessment record showed that the Assessing Officer sought particulars and supporting documents for Chapter VI-A deductions under Section 142(1), and the assessee furnished donation details and receipts. The claim was thus examined with application of mind. A different view on the deduction did not render the assessment erroneous.

Conclusion: The assessment order was neither erroneous nor prejudicial to the interests of the Revenue; revision under Section 263 was invalid, in favour of the assessee.

Final Conclusion: The revisionary order was quashed and the assessment allowing the Section 80G deduction for the qualifying corporate social responsibility donations remained undisturbed.

Ratio Decidendi: Revisionary jurisdiction cannot be invoked where an assessment, after inquiry and application of mind, adopts the legally sustainable view that disallowance of mandatory corporate social responsibility expenditure under Section 37(1) does not bar a qualifying Section 80G deduction.

Issues: Whether penalty for under-reporting of income under Section 270A of the Income-tax Act, 1961 could be sustained where the income declared in the original return and processed under Section 143(1) remained unchanged in reassessment without any addition or disallowance.

Analysis: Section 270A(2)(a) requires a comparison between the assessed income and the income determined on processing of the return to establish under-reporting. The original return disclosed income of Rs. 45,83,888, which was accepted on processing under Section 143(1). The same income was returned in response to reassessment proceedings and was ultimately accepted without any variation. The statutory conditions for treating the entire returned income as under-reported were therefore not established.

Conclusion: The penalty under Section 270A was unsustainable and was directed to be deleted.

Issues: Whether interest earned by a co-operative society from investments with a co-operative bank qualifies for deduction under Section 80P(2)(d) of the Income-tax Act, 1961.

Analysis: Section 80P(2)(d) permits deduction of interest or dividend income received from investments with another co-operative society. A co-operative bank remains a species of co-operative society for this purpose. Section 80P(4), which excludes a co-operative bank itself from claiming the deduction, does not disentitle a co-operative society from claiming deduction on interest received from a co-operative bank.

Conclusion: Interest received by the agricultural co-operative society from a co-operative bank is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, 1961, and the addition is deleted.

Issues: Whether the entire Rs. 12,03,500 cash-deposit addition under section 69A, taxable under section 115BBE, should be sustained where the supporting cash records were self-prepared and unaudited.

Analysis: Section 69A governs unexplained money, while the charge under the Income-tax Act is on income and not on gross receipts. The cash records, bank material and related documents produced did not justify complete acceptance because the books were self-prepared and not subject to audit. At the same time, the material did not warrant taxing the entire cash deposit as income. An estimated profit component was considered appropriate to account for the inconsistencies while protecting revenue.

Conclusion: The addition is restricted to Rs. 1,20,350, being 10% of Rs. 12,03,500, taxable at normal rates and not under section 115BBE; the issue is decided partly in favour of the assessee.

Issues: Whether estimated additions for alleged on-money receipts from sale of flats could be sustained under Section 69A of the Income-tax Act, 1961 without corroborative evidence of the assessee's receipt.

Analysis: The seized material evidenced on-money receipts of a specified amount which had been accepted as income and offered to tax by the person managing the project. The further additions were derived by applying an average sale rate to other flat sales, without material evidencing that the assessee had received additional on-money. An addition under Section 69A cannot rest solely on such uncorroborated estimation.

Conclusion: The estimated additions for alleged on-money receipts under Section 69A of the Income-tax Act, 1961 cannot be sustained and are deleted.

Issues: (i) Whether a 20% ad hoc disallowance of claimed business expenditure was sustainable without rejection of audited books or identification of bogus or unsupported expenditure; (ii) Whether the disallowance for cash payments under section 40A(3) required fresh verification of the payment recipients, business expediency, and the exceptions under Rule 6DD(e).

Issue (i): Whether a 20% ad hoc disallowance of claimed business expenditure was sustainable without rejection of audited books or identification of bogus or unsupported expenditure.

Analysis: The expense entries and apparent discrepancies in nomenclature were explained through ledger extracts, cash-book details, and supporting vouchers. The audited books were not rejected, no particular expenditure was found bogus or unsupported, and no defect was identified in the revised clarification. A blanket 20% disallowance founded merely on doubts arising from differently described entries was therefore conjectural.

Conclusion: The ad hoc disallowance of business expenditure is deleted in favour of the assessee.

Issue (ii): Whether the disallowance for cash payments under section 40A(3) required fresh verification of the payment recipients, business expediency, and the exceptions under Rule 6DD(e).

Analysis: Section 40A(3) restricts deductions for specified cash payments, while Rule 6DD(e) provides an exception for payments for specified animal-husbandry produce, including hides and skins. The record required verification of whether payments exceeding the threshold were made to different persons, whether business expediency justified the payments, and whether the statutory exception applied. These matters had not been adequately examined.

Conclusion: The cash-payment disallowance is set aside and remitted to the Assessing Officer for fresh verification and recomputation.

Final Conclusion: The unsupported ad hoc expense disallowance is removed, while the cash-payment question requires fresh statutory verification.

Ratio Decidendi: An ad hoc disallowance of expenditure cannot rest on conjecture where audited books are not rejected and no expenditure is found bogus or unsupported.

Issues: Whether rejection of the rectification application was valid where no mistake apparent from the record was established.

Analysis: Section 154 of the Income-tax Act, 1961 permits correction only of a mistake apparent from the record and cannot be invoked to review or reopen an issue requiring reconsideration beyond that limited jurisdiction. The original appeal had not been admitted under Section 249(3) of the Income-tax Act, 1961 because the delay in filing it was not condoned. The rectification application did not demonstrate any apparent mistake in that order. The grounds concerning the merits of the deduction claim and consequential interest were not adjudicated because the appeal was confined to rejection of rectification.

Conclusion: Rejection of the rectification application was valid; the issue is decided against the assessee.

Issues: Whether interest earned on fixed deposits and Kisan Vikas Patras, though assessable under the head income from other sources, must be included in book profit for computing the ceiling of partners' remuneration under Section 40(b) of the Income-tax Act, 1961.

Analysis: Explanation 3 to Section 40(b) adopts the net profit shown in the partnership firm's profit and loss account as the basis for book profit. The applicable measure is the commercial profit reflected in that account, rather than only the income computed under the head profits and gains of business or profession. The interest income formed part of the profit and loss account, and no contrary authority was shown to justify its exclusion from book profit.

Conclusion: Interest on fixed deposits and Kisan Vikas Patras included in the profit and loss account cannot be excluded while determining book profit for allowable partners' remuneration; the consequential disallowance was deleted.

Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for Assessment Year 2016-17 was barred by limitation, thereby invalidating the reassessment.

Analysis: Section 149(1)(a) permitted reassessment notice within three years from the end of the relevant assessment year. The extended period under Section 149(1)(b) was available only where the prescribed material revealed escaped income of at least Rs. 50 lakhs. The recorded figure of Rs. 57,57,235 included Rs. 17,00,500 twice, as that amount formed part of the total cash deposits of Rs. 26,30,500. After excluding the duplicate counting of income, the alleged escaped income was Rs. 40,56,735, below the statutory threshold. A valid jurisdictional notice within limitation was necessary to assume reassessment jurisdiction.

Conclusion: The notice dated 27.03.2023 was barred by limitation; consequently, the reassessment order was without jurisdiction and stood quashed.

Issues: (i) Whether renewal registration under Section 12AB could be refused solely because the educational society charged substantial fees and generated surplus; (ii) Whether the delay in filing Form 10AB should be condoned.

Issue (i): Whether renewal registration under Section 12AB could be refused solely because the educational society charged substantial fees and generated surplus.

Analysis: Section 2(15) recognises education as a charitable purpose, and the inquiry at the registration stage under Section 12AB focuses on the society's objects and the genuineness of its activities. The educational objects and their implementation were undisputed. The surplus was generated from educational activities, applied or accumulated for those objects, and was not diverted for non-charitable purposes or for the benefit of members. Fees charged and the quantum of surplus, by themselves, do not establish a profit-making motive where the surplus is incidental to imparting education.

Conclusion: Renewal registration under Section 12AB cannot be denied merely because fees are substantial or surplus is generated; the society is entitled to registration.

Issue (ii): Whether the delay in filing Form 10AB should be condoned.

Analysis: The authority did not specifically adjudicate limitation, while the society had filed a condonation request explaining the delay. The explanation furnished warranted condonation.

Conclusion: The delay in filing Form 10AB is condoned.

Final Conclusion: The authority is required to condone the delay and grant registration under Section 12AB pursuant to the renewal application.

Ratio Decidendi: At the registration stage, incidental surplus from educational activities cannot alone negate charitable status where the institution pursues its educational objects and does not divert funds for non-charitable purposes.

Issues: (i) Whether refusal to condone the delay in filing the first appeal warranted restoration for examination of the addition for unexplained money; (ii) Whether the penalty founded on the addition could survive after the quantum matter was restored for fresh adjudication.

Issue (i): Whether refusal to condone the delay in filing the first appeal warranted restoration for examination of the addition for unexplained money.

Analysis: The assessment was completed ex parte by treating cash deposits as unexplained money under Section 69A of the Income-tax Act, 1961 and applying Section 115BBE of the Income-tax Act, 1961. The explanation that the deposits related to transactions undertaken as a Banking Mitra on behalf of the bank and its customers, with only commission constituting income, had not been tested against supporting material. In the interest of substantial justice, verification of bank records, appointment documents, transaction particulars and commission statements was required with a reasonable opportunity of hearing.

Conclusion: In favour of the assessee, the assessment and appellate orders were set aside and the matter was restored for de novo adjudication of the nature and source of the deposits.

Issue (ii): Whether the penalty founded on the addition could survive after the quantum matter was restored for fresh adjudication.

Analysis: The penalty under Section 271AAC(1) of the Income-tax Act, 1961 was consequential upon the addition that had been set aside for fresh determination.

Conclusion: In favour of the assessee, the existing penalty was deleted, without precluding fresh penalty proceedings in accordance with law if warranted by the reassessment outcome.

Final Conclusion: The taxability of the deposits requires fresh evidentiary verification, and the existing penalty order ceases to operate pending that determination.

Issues: (i) Whether long-term capital gain claimed as exempt on sale of penny-stock shares could be assessed as unexplained cash credit; (ii) Whether penalty for the resulting non-genuine share transaction was sustainable.

Issue (i): Whether long-term capital gain claimed as exempt on sale of penny-stock shares could be assessed as unexplained cash credit.

Analysis: Under Section 68 of the Income-tax Act, 1961, the claim for exemption under Section 10(38) was tested against specific investigation material, the financial and market behaviour of the scrip, and the surrounding circumstances. Routing transactions through a recognised stock exchange and banking channels was not by itself conclusive of genuineness. The abnormal price appreciation, absence of comparable investment activity, and failure to rebut the investigation findings or substantiate the acquisition of shares sustained the Revenue's case on the preponderance of probabilities and evidential burden principles.

Conclusion: The claimed long-term capital gain was treated as non-genuine and the addition as unexplained cash credit under Section 68 read with Section 115BBE of the Income-tax Act, 1961, was sustained against the assessee.

Issue (ii): Whether penalty for the resulting non-genuine share transaction was sustainable.

Analysis: The penalty under Section 271(1)(c) of the Income-tax Act, 1961 was founded on the same addition, which remained sustained. Disclosure of the share transactions in the return did not displace the finding that they were non-genuine accommodation entries.

Conclusion: The penalty under Section 271(1)(c) of the Income-tax Act, 1961 was sustained against the assessee.

Final Conclusion: The exemption claim and its consequential penal liability failed because the impugned share receipts were not established as genuine transactions.

Ratio Decidendi: Stock-exchange routing and banking documentation do not by themselves establish the genuineness of a share transaction where specific investigation material and surrounding circumstances show it to be an accommodation entry and remain unrebutted.

Issues: Whether the claimed deduction for a political donation was allowable under Section 80GGC of the Income-tax Act, 1961.

Analysis: Section 80GGC permits deduction only for a genuine qualifying contribution. The investigation material, statements recorded during search, bank-trail analysis, and the established modus operandi of systematic layering of funds showed that the recipient political party was used for accommodation entries. Applying the test of human probabilities and preponderance of probabilities, payment through banking channels and production of a donation receipt did not establish the genuineness of the contribution or displace the evidence that the apparent transaction was not real.

Conclusion: The claimed political donation was not genuine and the deduction under Section 80GGC of the Income-tax Act, 1961 was not allowable; the issue is decided against the assessee.

Issues: Whether deduction under Section 80GGC of the Income-tax Act, 1961 was allowable in respect of the claimed donation to a registered unrecognised political party.

Analysis: Section 80GGC of the Income-tax Act, 1961 permits deduction only for a genuine qualifying political contribution. Payment through banking channels and production of a donation receipt were insufficient where investigation material, unrecanted statements, bank-trail analysis and the established modus operandi of the recipient political party demonstrated systematic accommodation-entry activity. Applying the test of human probabilities and preponderance of probabilities, the apparent transaction was found not to represent its real character.

Conclusion: The claimed contribution was not a genuine donation eligible for deduction under Section 80GGC of the Income-tax Act, 1961; the disallowance was sustained against the assessee.

Issues: Whether an addition of Rs. 8,00,000 as unexplained expenditure under Section 69C read with Section 115BBE could be sustained despite acceptance of presumptive income declared under Section 44AD.

Analysis: The declared turnover, sales and presumptive income computed at the prescribed rate under Section 44AD were accepted. Maintenance of books of account is not mandatory under that presumptive-taxation provision. In the absence of any disturbance to the accepted turnover or presumptive income, the absence of transportation particulars, GST details, cash-book entries or supporting purchase records could not, by itself, justify the addition. The precise nature of the facilitator's business was also not determinative of the claimed purchases.

Conclusion: The addition of Rs. 8,00,000 under Section 69C read with Section 115BBE was unsustainable and was deleted, in favour of the assessee.

Issues: (i) Whether cash entries in a seized electronic worksheet, search statements and statutory presumptions could substantiate substantive additions as the individual assessee's undisclosed income; (ii) Whether the aggregate cash receipts in the seized worksheet could be wholly assessed as the assessee-company's undisclosed income or whether the restriction of additions to 25% was sustainable.

Issue (i): Whether cash entries in a seized electronic worksheet, search statements and statutory presumptions could substantiate substantive additions as the individual assessee's undisclosed income.

Analysis: Sections 132(4A) and 292C of the Income-tax Act, 1961 create rebuttable evidentiary presumptions concerning seized material, while a statement under Section 132(4) is relevant evidence. However, neither the presumptions nor the statements establish personal beneficial ownership or attribution of income without material connecting the entries to the individual. The worksheet was found on a computer used by an employee at the assessee-company's premises; it did not identify the individual as recipient or beneficiary, and no corresponding undisclosed cash, asset, investment, personal expenditure or financial trail was found. The statements referred to company and group business transactions and did not contain an unequivocal admission of personal receipt or appropriation. The absence of a specific opportunity to answer the proposed personal attribution reinforced the evidentiary deficiency. Suspicion arising from managerial association could not take the place of proof.

Conclusion: The substantive additions as the individual assessee's undisclosed income were unsustainable and were rightly deleted in full, in favour of the assessee.

Issue (ii): Whether the aggregate cash receipts in the seized worksheet could be wholly assessed as the assessee-company's undisclosed income or whether the restriction of additions to 25% was sustainable.

Analysis: The seized worksheet, the search statements and the physical cash found supported the existence of cash transactions outside the regular accounts. Nevertheless, the worksheet contained negative balances, discontinuities and arithmetical inconsistencies, and comprised receipts and payments involving withdrawals from disclosed sources, multiple group entities and possible cash recycling. The approximate correspondence between the worksheet's closing balance and cash found established only a relevant corroborative circumstance, not that every gross receipt was fresh taxable income. Although the books were not rejected under Section 145 of the Income-tax Act, 1961, that circumstance was not conclusive; the decisive deficiency was the failure to identify specific fictitious expenditure, correlate it with claimed deductions, segregate entity-wise transactions, or establish the net income component. The presumptions under Sections 132(4A) and 292C did not convert gross running cash entries into taxable income. In these circumstances, estimation of the unaccounted income element at 25% was a permissible assessment of the available evidence.

Conclusion: The restriction of additions to 25% of the recorded amounts and deletion of the remaining 75% were sustained, in favour of the assessee.

Final Conclusion: The seized material could support only an estimated addition in the assessee-company's hands, while it did not establish that any part of the recorded transactions was income personally attributable to the individual assessee.

Ratio Decidendi: Rebuttable presumptions attached to seized documents and search statements do not dispense with proof of the person to whom income is attributable or the taxable character and quantum of running cash entries; aggregate receipts cannot be assessed as income without a reliable nexus to the relevant taxable transaction.

Issues: (i) Whether an earlier decision concerning classification of a cement unit under IPR 2007 governs the VAT-reimbursement claim; (ii) Whether refusal to consider an existing unit's claim for downstream Thrust Sector recognition and VAT reimbursement solely because it was not a new industrial unit is sustainable.

Issue (i): Whether an earlier decision concerning classification of a cement unit under IPR 2007 governs the VAT-reimbursement claim.

Analysis: The earlier ruling requires Negative List classification to be based on the unit's actual industrial activity and value addition, rather than on grinding or mixing as an isolated component of the manufacturing process. However, that matter involved an issued eligibility certificate and a sanctioned reimbursement, whereas the present claim had not reached final sanction or quantification.

Conclusion: The earlier decision is relevant to the classification exercise but does not establish an automatic entitlement to VAT reimbursement.

Issue (ii): Whether refusal to consider an existing unit's claim for downstream Thrust Sector recognition and VAT reimbursement solely because it was not a new industrial unit is sustainable.

Analysis: Clause 18.4(iv) of IPR 2007 covers existing industrial units undertaking expansion, modernisation or diversification. The retrospective amendment deleting the word "new" from the relevant Annexure entries removed the sole basis stated for withholding consideration. The verification and inspection reports recorded substantial post-policy expansion investment, increased capacity, employment, and utilisation of waste products, providing material support for downstream industry status and eligibility for fiscal incentives. Those materials did not, however, amount to a final sanction or quantify the reimbursement. The remaining prescribed criteria require a reasoned administrative decision.

Conclusion: The refusal founded solely on the original unit not being new is unsustainable; downstream Thrust Sector eligibility must be determined on the applicable criteria, followed by determination of admissible VAT reimbursement if such status is affirmed.

Final Conclusion: The retrospective removal of the new-unit condition requires a merits-based determination of downstream Thrust Sector eligibility, after which any reimbursement admissible for increased commercial production is to be quantified under IPR 2007.

Ratio Decidendi: Where an industrial policy retrospectively removes a new-unit requirement and expressly covers expansion of existing units, eligibility cannot be denied solely because the original unit pre-dated the policy; the remaining eligibility conditions must be assessed on the unit's actual operations and record.

Issues: Whether the plaint could be amended to add claims for compensation awarded in cheque-dishonour proceedings, interest, and litigation expenses.

Analysis: The compensation had been determined in criminal proceedings and was recoverable through the statutory enforcement procedure under the Bharatiya Nagarik Suraksha Sanhita, 2023 or the Code of Criminal Procedure, 1973, rather than through the pending civil recovery suit. The proposed claim founded on the criminal compensation order, as well as the claim for expenses incurred in criminal litigation, arose from a cause of action distinct from that pleaded in the suit. Although amendments necessary to resolve the real controversy are ordinarily permissible, an amendment introducing an entirely new cause of action or changing the nature of the suit is impermissible.

Conclusion: The proposed amendment was impermissible; the criminal compensation could not be recovered through the civil suit, and the litigation-expense claim rested on a distinct cause of action.

Issues: (i) Validity of the provisional attachments of the petitioner's bank accounts under Section 83 of the Central Goods and Services Tax Act, 2017; (ii) Attachability of balances in RBI-regulated escrow accounts as the petitioner's property under Section 83 of the Central Goods and Services Tax Act, 2017.

Issue (i): Validity of the provisional attachments of the petitioner's bank accounts under Section 83 of the Central Goods and Services Tax Act, 2017.

Analysis: Section 83 permits provisional attachment only upon formation of an opinion, founded on tangible material, that attachment is necessary to protect Government revenue. The power is draconian and must be exercised with proportionality; necessity cannot be equated with expediency or a mere prima facie suspicion. The attachment orders did not identify any GST liability of the petitioner, its role in any identified tax evasion, the specific transactions involved, or material establishing that the petitioner fell within the statutory classes whose property could be attached. Vague allegations concerning third-party online gaming entities, money laundering, and alleged non-cooperation did not establish the statutory preconditions. Reasons not contained in the attachment orders could not be supplied through an affidavit-in-reply.

Conclusion: The statutory preconditions for provisional attachment, including tangible material and a reasoned opinion of necessity, were absent; the provisional attachments were unlawful.

Issue (ii): Attachability of balances in RBI-regulated escrow accounts as the petitioner's property under Section 83 of the Central Goods and Services Tax Act, 2017.

Analysis: Section 83 authorises attachment only of property belonging to a taxable person or a person covered by Section 122(1A). The escrow balances represented merchant settlement amounts payable to identified beneficiaries and were impressed with a trust. They did not belong to the petitioner. A prospective liability of third-party merchants could not justify attachment of a payment aggregator's escrow funds in the absence of material showing the aggregator's own GST liability.

Conclusion: The escrow balances were not attachable as property of the petitioner.

Final Conclusion: Investigative suspicion regarding third-party tax evasion, without substantiated material linking the petitioner to a GST liability or demonstrating the necessity of attachment, could not sustain the account freezes.

Ratio Decidendi: Provisional attachment under Section 83 requires tangible material establishing both the statutory status of the person concerned and the necessity of attachment to protect Government revenue; vague suspicion and unsupported allegations of non-cooperation are insufficient.