Issues: Whether the assessment order under Section 153C of the Income-tax Act, 1961 for assessment year 2010-11 was barred by statutory limitation.

Analysis: The satisfaction note was recorded in assessment year 2022-23. Under Sections 153A and 153C of the Income-tax Act, 1961, where the alleged escaped income exceeded Rs. 50 lakh, the applicable limitation extended to ten assessment years calculated backwards from that assessment year. The ten-year period extended only up to assessment year 2013-14; assessment year 2010-11 fell outside that period. The assessment was therefore a time-barred assessment.

Conclusion: The assessment order for assessment year 2010-11 was barred by statutory limitation, in favour of the assessee.

Issues: (i) Whether offshore supply receipts under the first contract were taxable in India on the basis that a turnkey contract had been artificially split, the supplies were on CIF terms, and title passed only upon acceptance testing; (ii) Whether the Indian associate constituted a fixed place permanent establishment or dependent agent permanent establishment, creating a business connection and permitting attribution of offshore-supply profits; (iii) Whether Section 44BBB of the Income-tax Act, 1961 could be applied to compute income from the offshore supplies.

Issue (i): Whether offshore supply receipts under the first contract were taxable in India on the basis that a turnkey contract had been artificially split, the supplies were on CIF terms, and title passed only upon acceptance testing.

Analysis: Under Section 9(1)(i) of the Income-tax Act, 1961 and Article 7 of the India-Finland Double Taxation Avoidance Agreement, only income attributable to operations carried out in India may be taxed in India. The contractual arrangement comprised distinct offshore supply, onshore supply and onshore service contracts, and was not an artificial splitting of a single indivisible contract. The offshore contract was confined to supplies from abroad; title and payment were outside India. CIF terms, continuing responsibility for care and custody, performance guarantees, and acceptance testing did not defer transfer of title or convert the offshore transaction into an Indian taxable operation.

Conclusion: The offshore supply receipts were not taxable in India, in favour of the assessee.

Issue (ii): Whether the Indian associate constituted a fixed place permanent establishment or dependent agent permanent establishment, creating a business connection and permitting attribution of offshore-supply profits.

Analysis: Article 5(1) and Article 5(5) of the India-Finland Double Taxation Avoidance Agreement require evidence of a fixed place at the assessee's disposal or of an agent acting dependently with requisite authority. The Indian associate conducted its own substantial and independent business. Its limited participation in customer meetings in relation to its own onshore scope did not establish an agency relationship or a permanent establishment. The survey material did not concern the assessee and did not establish the required nexus with the offshore supplies.

Conclusion: The Indian associate was neither a fixed place permanent establishment nor a dependent agent permanent establishment of the assessee, and no business connection or offshore-profit attribution arose, in favour of the assessee.

Issue (iii): Whether Section 44BBB of the Income-tax Act, 1961 could be applied to compute income from the offshore supplies.

Analysis: Section 44BBB of the Income-tax Act, 1961 concerns income of a foreign company from specified turnkey power-project activities and does not extend to revenue solely from offshore supply where property in the goods transferred outside India. Its application also lacked the necessary foundation of a permanent establishment or taxable Indian operations.

Conclusion: Section 44BBB of the Income-tax Act, 1961 was inapplicable to the offshore supply receipts, in favour of the assessee.

Final Conclusion: The addition relating to offshore supply receipts was deleted, as the supplies had no taxable territorial nexus with India and could not be subjected to presumptive computation.

Issues: (i) Whether the 2025 Customs Brokers Licensing Examination was invalid because 65 of 150 questions concerned Allied Acts, allegedly departing from past examination patterns; (ii) Whether the alleged out-of-syllabus, ambiguous, or difficult questions and answer-key errors warranted judicial interference, licences, or additional examination attempts.

Issue (i): Whether the 2025 Customs Brokers Licensing Examination was invalid because 65 of 150 questions concerned Allied Acts, allegedly departing from past examination patterns.

Analysis: Regulation 6(7) of the Customs Brokers Licensing Regulations, 2018 expressly permits questions on Allied Acts and other laws relevant to EXIM trade and customs clearance. The Regulation prescribes no numerical ratio or ceiling for questions from major Acts and Allied Acts. A pattern followed in earlier examinations does not create a binding restriction upon the expert examining authority.

Conclusion: The proportion of questions from Allied Acts did not invalidate the examination. The issue was decided against the petitioners.

Issue (ii): Whether the alleged out-of-syllabus, ambiguous, or difficult questions and answer-key errors warranted judicial interference, licences, or additional examination attempts.

Analysis: Judicial review under Article 226 of the Constitution of India is confined to patent illegality, mala fides, arbitrariness, or manifest error in the examination process. The expert-verified answer key carries a presumption of correctness, rebuttable only by a glaring error apparent without inferential reasoning. The objections disclosed, at most, questions of drafting precision, interpretation, or difficulty; they did not establish a facially demonstrable error in the answers or a departure from the notified syllabus. The framing, standard, and assessment of examination questions remain within the domain of subject experts.

Conclusion: No patent defect in the questions or answer key was established, and no entitlement to licences or additional attempts arose. The issue was decided against the petitioners.

Final Conclusion: The examination and its expert evaluation remain undisturbed, as the writ jurisdiction cannot be used to reassess academic choices absent a patent and demonstrable defect.

Ratio Decidendi: In competitive examinations, an expert-approved question paper and answer key may be displaced in judicial review only upon a patent, facially demonstrable error or arbitrariness; an unstipulated departure from past question patterns or mere difficulty is insufficient.

Issues: (i) Whether customs duty collected upon release of the detained gold jewellery could be quashed despite an unchallenged adjudication order making release conditional upon payment of such duty; (ii) Whether the detention charges were liable to be quashed as unlawful.

Issue (i): Whether customs duty collected upon release of the detained gold jewellery could be quashed despite an unchallenged adjudication order making release conditional upon payment of such duty.

Analysis: The adjudication order expressly permitted release only upon payment of redemption fine, applicable customs duty and penalty. The assessee did not challenge that order or pursue remedies against its conditions. The earlier writ proceedings directed release in accordance with that order and did not adjudicate its validity. A belated challenge to the duty condition through the present writ amounted to an impermissible indirect challenge to the unchallenged order.

Conclusion: Against the assessee: the customs-duty recovery could not be quashed.

Issue (ii): Whether the detention charges were liable to be quashed as unlawful.

Analysis: No material established that the warehouse detention charges were recovered contrary to the governing statutory provisions.

Conclusion: Against the assessee: the detention charges were not liable to be quashed.

Final Conclusion: The conditions for release under the unchallenged adjudication order remain binding, and the recoveries made pursuant to those conditions stand enforceable.

Ratio Decidendi: An unchallenged adjudication order cannot be collaterally assailed in writ proceedings merely because its conditions have been implemented.

Issues: (i) Whether the extended period of limitation was validly invoked for recovery of unpaid service tax; (ii) Whether interest and penalties for non-payment and concealment of collected service tax were sustainable.

Issue (i): Whether the extended period of limitation was validly invoked for recovery of unpaid service tax.

Analysis: The service tax collected from service recipients for the disputed period was neither deposited nor disclosed in the balance sheets, and the statutory returns for that period were not filed. Section 73A of the Finance Act, 1994 mandates the immediate deposit of collected service tax. The non-disclosure of collected tax and prolonged non-payment constituted suppression of facts and intentional evasion, attracting the proviso to Section 73(1) of the Finance Act, 1994.

Conclusion: The extended period of limitation was validly invoked and the service-tax demand was sustainable, against the assessee.

Issue (ii): Whether interest and penalties for non-payment and concealment of collected service tax were sustainable.

Analysis: Statutory interest under Section 75 of the Finance Act, 1994 followed the confirmed tax demand. Failure to pay the collected tax attracted penalty under Section 77, while the established suppression of facts justified penalty under Section 78 of the Finance Act, 1994.

Conclusion: Interest and penalties under Sections 75, 77 and 78 of the Finance Act, 1994 were sustainable, against the assessee.

Final Conclusion: The liability arising from collection, non-deposit and concealment of service tax, together with consequential interest and penalties, remained enforceable.

Ratio Decidendi: Collection of service tax without its deposit or disclosure in statutory returns and accounts constitutes suppression of facts, justifying invocation of the extended limitation period and penal consequences.

Issues: Whether the first appellate order was sustainable where the adjournment request was not considered, the appellant was not afforded a hearing, and the order did not state reasons for its decision.

Analysis: Section 107(8) of the Punjab Goods and Services Tax Act, 2017 requires the Appellate Authority to afford an opportunity of hearing. Under Section 107(11), it must make necessary inquiry and confirm, modify or annul the challenged order; Section 107(12) requires a written order stating the points for determination, the decision and reasons. Non-appearance may permit ex parte adjudication, but does not permit dismissal for want of prosecution without a merits determination. The cryptic statement that the grounds were perused and that no interference was required did not satisfy the requirement of a speaking order.

Conclusion: The Order-in-Appeal was unsustainable for breach of principles of natural justice and the statutory duty to issue a reasoned decision on merits; the penalty merits were left open for fresh determination after hearing.

Issues: Whether a commercial suit involving a corporate debtor in liquidation could continue without leave of the Tribunal, and whether it could be maintained against the remaining defendant after deletion of the corporate debtor.

Analysis: Section 279(1) of the Companies Act, 2013 and Section 33(5) of the Insolvency and Bankruptcy Code, 2016 bar the continuation of proceedings by or against a company in liquidation without the Tribunal's leave. No such leave had been obtained, and the liquidator had not been served in the pending suit. The reliefs arose from the subcontractual arrangement and were sought jointly against the principal employer and the corporate debtor; the suit could not therefore be sustained by excluding the corporate debtor.

Conclusion: The suit could not proceed without leave of the Tribunal, and neither the suit nor the appellate challenge could be maintained by deleting the corporate debtor in liquidation.

Issues: Whether confirmation of the provisional attachment was sustainable without establishing that the attached bank balance represented proceeds of crime derived from a scheduled offence.

Analysis: Under the Prevention of Money Laundering Act, 2002, attachment requires an identifiable nexus between the property and proceeds of crime connected with a scheduled offence. The material showed that no fintech or service-provider entity operated the appellant's lending application, and the predicate-offence chargesheets neither arraigned the appellant nor attributed the alleged criminal activity to its application. The alleged commission income was not linked to any identified proceeds of crime, and the outstanding component of a contractual loan could not, without further material, be characterised as proceeds of crime. The available bank balance was also not specifically traced to any scheduled offence.

Conclusion: The requisite nexus between the attached property and proceeds of crime was not established; the property could not be treated as proceeds of crime.

Issues: Whether a writ petition challenging a GST demand should be entertained despite the statutory appellate remedy.

Analysis: The objections concerning the alleged divergence between the show-cause notice and the confirmed demand, classification under tariff headings, applicable notifications, opportunity of hearing, and cross-examination required factual scrutiny. Such matters were not apparent on the face of the record and fell within the jurisdiction of the Appellate Authority. Section 107 of the Central Goods and Services Tax Act, 2017 provides an efficacious appellate remedy, including hearing, prescribed pre-deposit and consequential stay of recovery for the balance disputed amount.

Conclusion: Writ jurisdiction under Article 226 of the Constitution of India was not to be exercised where the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017 was available; the grievances must be pursued before the Appellate Authority.

Issues: (i) Adequacy of the show-cause notice in light of the portal-generated DRC-01, the departmental communication and the DRC-06 replies; (ii) Effect of non-grant of requested personal hearing under Section 75(4), including whether remand was required; (iii) Whether pre-10.07.2024 credit of sufficient cash in the Electronic Cash Ledger discharged the return liability and stopped interest under Section 50; (iv) Temporal effect of the proviso inserted in Rule 88B(1) by Notification No. 12/2024-Central Tax dated 10.07.2024; (v) Whether the interest demands and consequential refund or adjustment prayers required interference.

Issue (i): Adequacy of the show-cause notice in light of the portal-generated DRC-01, the departmental communication and the DRC-06 replies.

Analysis: The notice material and contemporaneous replies disclosed the basis and computation of the proposed interest demand. The departmental communication was admittedly received, and the DRC-06 replies addressed the ECL-credit contention, relevant challans and CINs. No material defence was shown to have been excluded for want of particulars; hence, no prejudice arose from the disputed formal status of that communication as an annexure to DRC-01.

Conclusion: The notice challenge fails for want of demonstrated prejudice, against the assessee.

Issue (ii): Effect of non-grant of requested personal hearing under Section 75(4), including whether remand was required.

Analysis: Section 75(4) required a hearing because one was specifically sought and an adverse decision was contemplated. Its breach was established. However, Section 113(1) permitted final appellate determination, and the factual record was complete: ECL sufficiency, continuity of balances and computations were undisputed, while the remaining controversy was purely statutory. No additional material or defence requiring a fresh original hearing was identified. The prejudice requirement and the principle that remand should not be an empty formality therefore applied.

Conclusion: Non-compliance with Section 75(4) was established in favour of the assessee, but no remand was warranted; the request for remand was rejected.

Issue (iii): Whether pre-10.07.2024 credit of sufficient cash in the Electronic Cash Ledger discharged the return liability and stopped interest under Section 50.

Analysis: Section 49(1) treats an incoming amount as a deposit credited to the Electronic Cash Ledger, while Section 49(3) separately permits its use for payment. Rule 85(3) identifies debit of the relevant electronic ledger as the statutory act discharging a return liability. Rule 87(6) and the Explanation to Section 49 establish receipt of funds in the Government banking channel upon ECL credit, but do not appropriate that general deposit to a particular monthly liability. The retrospective proviso to Section 50(1) and Rule 88B(1) expressly refer to tax paid by debiting the Electronic Cash Ledger and calculate interest for delay in furnishing the return. This statutory discharge mechanism prevailed despite the compensatory character of interest.

Conclusion: For the relevant periods, ECL credit without debit or appropriation did not discharge the return-specific tax liability or terminate Section 50 interest, against the assessee.

Issue (iv): Temporal effect of the proviso inserted in Rule 88B(1) by Notification No. 12/2024-Central Tax dated 10.07.2024.

Analysis: The new proviso excludes, from interest computation, amounts credited in the Electronic Cash Ledger by the due date and continuously retained until debit. Unlike Notification No. 14/2022-Central Tax, which expressly gave Rule 88B retrospective operation from 01.07.2017, Notification No. 12/2024-Central Tax contains no retrospective or deeming clause. The legislative history also showed that the amendment introduced a substantive relief from the previously understood debit-based rule rather than merely clarifying earlier law.

Conclusion: The 2024 proviso operates prospectively from 10.07.2024 and does not apply to the disputed earlier periods, against the assessee.

Issue (v): Whether the interest demands and consequential refund or adjustment prayers required interference.

Analysis: Since the pre-10.07.2024 ECL balances did not amount to statutory payment of the return liabilities, interest remained chargeable until debit of the Electronic Cash Ledger upon furnishing the delayed returns. The admitted interest and all prior payments, deposits, recoveries and adjustments remained subject to demand-wise reconciliation to prevent double recovery.

Conclusion: The disputed interest demands and refund claim founded on their alleged illegality required no interference, in favour of Revenue; only consequential reconciliation of amounts already accounted for remained available.

Final Conclusion: For periods preceding 10.07.2024, an unappropriated Electronic Cash Ledger deposit remained distinct from statutory payment of the corresponding return liability, and the later exclusion for continuously retained ECL balances did not alter that position retrospectively.

Ratio Decidendi: Under the pre-10.07.2024 GST framework, credit of money to the Electronic Cash Ledger is a general deposit and becomes payment of a return-specific tax liability only upon debit or appropriation through the prescribed ledger mechanism; a later exclusion without retrospective language does not govern prior periods.

Issues: (i) Whether the notice proceedings were invalid for want of adequate notice and resulting prejudice; (ii) Whether the denial of a requested personal hearing required remand under Section 75(4); (iii) Whether a sufficient pre-due-date credit in the Electronic Cash Ledger constituted payment of the return liability and stopped interest under Section 50 before ledger debit; and (iv) Whether the proviso inserted in Rule 88B(1) on 10.07.2024 operated retrospectively or merely declared the pre-existing law.

Issue (i): Whether the notice proceedings were invalid for want of adequate notice and resulting prejudice.

Analysis: The portal-generated notice, read with the contemporaneously received communication containing the basis and computation of interest, was sufficiently understood and answered through detailed DRC-06 replies. The formal dispute over whether the communication was annexed to DRC-01 caused no demonstrated prejudice, since no material factual or legal defence was shown to have been foreclosed.

Conclusion: The notice proceedings were not invalid; this issue is against the assessee.

Issue (ii): Whether the denial of a requested personal hearing required remand under Section 75(4).

Analysis: Section 75(4) required a hearing where one was requested and an adverse decision was contemplated; its non-compliance was established. However, the appellate power to finally determine the matter permitted refusal of remand where the relevant ledger balances, challans, computations and the sole surviving statutory question were undisputed, and no additional defence or evidence was identified. Remand in those circumstances would be an empty formality without surviving prejudice.

Conclusion: The breach of Section 75(4) did not require remand; this issue is against the assessee.

Issue (iii): Whether a sufficient pre-due-date credit in the Electronic Cash Ledger constituted payment of the return liability and stopped interest under Section 50 before ledger debit.

Analysis: Section 39(7) fixed the due date for payment of self-assessed tax. Under Section 49, a deposit is credited to the Electronic Cash Ledger, whereas the balance is subsequently used for payment; Rule 85(3) identifies debit of the appropriate electronic ledger as the statutory act discharging the return liability. A CIN and the Explanation to Section 49, read with Rule 87(6), established receipt of funds in the Government banking channel but not appropriation to a particular monthly liability. The retrospective proviso to Section 50(1) and Rule 88B(1) expressly refer to tax paid by debiting the Electronic Cash Ledger and calculate interest for the delay in furnishing the return. Section 75(12) concerns recovery of unpaid self-assessed dues and does not alter the statutory payment mechanism. Late fee for delayed filing and interest on delayed statutory payment operate in distinct fields.

Conclusion: A cash credit in the Electronic Cash Ledger did not discharge the return liability or terminate Section 50 interest before ledger debit; this issue is against the assessee.

Issue (iv): Whether the proviso inserted in Rule 88B(1) on 10.07.2024 operated retrospectively or merely declared the pre-existing law.

Analysis: Notification No. 12/2024-Central Tax introduced an exclusion for amounts credited to and continuously retained in the Electronic Cash Ledger, but supplied no retrospective or deemed commencement clause. This contrasted with Notification No. 14/2022-Central Tax, which expressly deemed Rule 88B to have been inserted from 01.07.2017. The legislative context treated the 2024 proviso as a substantive relief from the earlier debit-based position rather than a clarification of it.

Conclusion: The 2024 proviso operates prospectively and is not declaratory of the pre-existing law for the periods concerned; this issue is against the assessee.

Final Conclusion: For the relevant pre-10.07.2024 periods, interest on the cash component continued until debit of the Electronic Cash Ledger towards the delayed return liability. Amounts already paid, deposited, recovered or adjusted require appeal-wise reconciliation to prevent double recovery.

Ratio Decidendi: Under the pre-10.07.2024 GST framework, an Electronic Cash Ledger deposit is distinct from statutory payment of a return liability, which occurs upon ledger debit; the later Rule 88B(1) exclusion for continuously available cash balances applies only prospectively absent express retrospective operation.

Issues: (i) Whether Geomembrane is classifiable under Tariff Sub-heading 59111000 as a textile product for technical use; (ii) Whether Geomembrane is covered by the applicable GST rate entries for Heading 5911.

Issue (i): Whether Geomembrane is classifiable under Tariff Sub-heading 59111000 as a textile product for technical use.

Analysis: HDPE strips having a width below 5 mm remain within Section XI under Note 1(g) and, after weaving, constitute textile fabric. The woven fabric is laminated on both sides with plastic and is supplied in pieces or cut to length for pond lining. Chapter Note 8(a)(i) to Chapter 59 includes textile fabrics coated, covered or laminated with other material, including plastic, where they are of a kind used for technical purposes. The use of the product in biofloc aquaculture ponds and water-conservation lining establishes the requisite technical use. The functional-use test and the relevant HSN notes therefore support classification under Heading 5911 rather than as an article of plastics.

Conclusion: Geomembrane is classifiable under Tariff Sub-heading 59111000 of the First Schedule to the Customs Tariff Act, 1975.

Issue (ii): Whether Geomembrane is covered by the applicable GST rate entries for Heading 5911.

Analysis: Classification under Tariff Sub-heading 59111000 brings the product within Heading 5911. Entry No. 168 of Schedule II to Notification No. 01/2017-Central Tax (Rate) covers Heading 5911 for the period up to 21.09.2025. Following supersession of that notification, Entry No. 386 of Schedule I to Notification No. 09/2025-Central Tax (Rate) covers Heading 5911 with effect from 22.09.2025.

Conclusion: Geomembrane is liable to GST at 12% up to 21.09.2025 and at 5% with effect from 22.09.2025.

Final Conclusion: The product is treated as a technical-use laminated textile under Heading 5911, with the corresponding GST entries governing the respective periods.

Ratio Decidendi: Woven HDPE strips of width not exceeding 5 mm, when laminated with plastic and used for a technical purpose, are classifiable as textile products for technical use under Heading 5911.

Issues: (i) Classification of outdoor playground equipment, outdoor gym equipment, and their spare parts, including bearings; (ii) Applicable GST rates for those goods under the rate notification.

Issue (i): Classification of outdoor playground equipment, outdoor gym equipment, and their spare parts, including bearings.

Analysis: Heading 9506 of Chapter 95 covers articles and equipment for general physical exercise and outdoor games. The HSN notes expressly include exercise apparatus within articles for general physical exercise and playground equipment such as swings, slides and see-saws within requisites for outdoor games. Chapter Note 3 provides that parts and accessories solely or principally used with Chapter 95 articles are classified with those articles. Bearings, however, are not confined to outdoor gym equipment and are specifically described under heading 8482; the specific-description rule in Rule 3(a) therefore applies.

Conclusion: Outdoor playground equipment and its eligible spare parts are classifiable under sub-heading 95069990; outdoor gym equipment and its eligible spare parts are classifiable under sub-heading 95069190. Bearings are classifiable under heading 8482, with the precise tariff item dependent on their specifications.

Issue (ii): Applicable GST rates for those goods under the rate notification.

Analysis: Schedule I entry 499 applies to sports goods other than articles and equipment for general physical exercise, while Schedule II entry 619 applies to articles and equipment for general physical exercise. Playground equipment qualifies as sports goods for children, whereas outdoor gym equipment is equipment for general physical exercise. Bearings fall within Schedule II entry 467.

Conclusion: Outdoor playground equipment and its eligible spare parts are taxable at 5%. Outdoor gym equipment, its eligible spare parts, and bearings are taxable at 18%.

Final Conclusion: The ruling distinguishes playground sports goods from general physical-exercise equipment for rate purposes and excludes bearings from classification as equipment-specific spare parts.

Ratio Decidendi: Parts solely or principally used with Chapter 95 equipment ordinarily follow that equipment, but an item specifically described under a separate tariff heading must be classified under that specific heading in preference to the general parts classification.

Issues: (i) Whether prosecution for failure to furnish a return under Section 276CC was sustainable where the tax payable by the assessee was neither determined nor alleged to be due; (ii) Whether the statutory presumption of culpable mental state and wilful non-filing of the return were established.

Issue (i): Whether prosecution for failure to furnish a return under Section 276CC was sustainable where the tax payable by the assessee was neither determined nor alleged to be due.

Analysis: The quantum of tax payable is material both to the prescribed punishment and to the exemption under proviso (ii)(b) to Section 276CC, which precludes prosecution where the relevant tax payable does not exceed the stipulated threshold. Although regular assessment is not invariably a precondition where the complaint establishes that tax was due, the complaint did not state that any tax was payable. The assessee had instead claimed a refund, and no assessment in any form determined a tax liability.

Conclusion: On the facts, prosecution under Section 276CC was unsustainable because the requisite tax liability was not established.

Issue (ii): Whether the statutory presumption of culpable mental state and wilful non-filing of the return were established.

Analysis: The presumption under Section 278E was rebutted by evidence that the property was jointly acquired, was funded by the husband through borrowing, and that the sale consideration was received by him. These circumstances did not disclose an intention to evade tax.

Conclusion: The non-filing of the return was not proved to be wilful, and the presumption of culpable mental state stood rebutted.

Final Conclusion: The essential ingredients for criminal liability for failure to furnish the return were not established.

Ratio Decidendi: A prosecution under Section 276CC cannot be sustained where tax liability is not shown in the complaint or otherwise established and the assessee rebuts the statutory presumption of culpable mental state by demonstrating absence of wilful default.

Issues: Whether the notice issued under Section 153C for assessment year 2012-13 was within the statutory limitation period.

Analysis: The satisfaction note was recorded in assessment year 2025-26. Even applying the extended ten-year period applicable where escaped income exceeded the prescribed threshold, the limitation period reached only up to assessment year 2016-17 when computed backwards. Assessment year 2012-13 therefore fell outside the permissible period under Sections 153A and 153C.

Conclusion: The notice for assessment year 2012-13 was time-barred and invalid.

Issues: Whether LIBOR plus 200 basis points was the appropriate benchmark rate for imputing interest on delayed foreign-currency receivables for determining the arm's length price.

Analysis: Determination of the appropriate interest rate for delayed receivables is essentially factual and must reflect prevailing interest rates. As the receivables were denominated in foreign currency, the applicable foreign-currency interest rate was the appropriate benchmark. LIBOR was commonly used as the international banking benchmark at the relevant time. No material established that adoption of LIBOR plus 200 basis points was perverse or disregarded prevailing rates.

Conclusion: LIBOR for six months plus 200 basis points was rightly adopted as the appropriate interest rate for delayed foreign-currency receivables; no substantial question of law arose.

Issues: Validity of penalty proceedings under Section 271AAB(1) where the show-cause notices did not specify the applicable statutory limb.

Analysis: Section 271AAB(1) contemplates distinct statutory limbs and conditions for levy of penalty. The notices issued on different dates referred to different formulations of the provision but failed to identify the precise applicable limb or the conditions forming the basis of the proposed penalty. Such omission deprived the assessee of a clear and legally valid notice of the specific charge.

Conclusion: The penalty proceedings were invalid because the notices did not specify the applicable limb of Section 271AAB(1); the impugned penalty order was quashed, in favour of the assessee.

Issues: Whether the cash of Rs. 11,26,000 recovered from the appellant had a sufficient nexus with proceeds generated from the alleged illegal liquor transactions and was liable to remain under provisional attachment.

Analysis: The material connected the appellant's CL-2 warehouse with the double-trip liquor-supply arrangement involving repeated use of transport documents and consequent evasion of excise duty. The cash recovered during search was not supported by an independently verifiable bank withdrawal or contemporaneous documentary proof of receipts from traders. The cash book was not treated as sufficient independent corroboration, and the stock-register explanation did not disprove unrecorded transactions. The cumulative material, including the unexplained cash, the alleged transactions benefiting the appellant, and the evidence of excise-duty evasion, established the requisite nexus.

Conclusion: The recovered cash constituted proceeds of crime and its provisional attachment was sustained.