PMLA attachment of mortgaged land alleged to be proceeds of crime is not displaced solely by a prior mortgage or SARFAESI enforcement. PMLA and SARFAESI operate in distinct fields, with PMLA prevailing on matters of money laundering and proceeds of crime, while attachment does not itself void the prior charge. A secured creditor seeking release must establish bona fides and adequate due diligence, particularly where its interest arose after or around the underlying criminal activity. The FIR registration date does not determine priority if the criminal activity predated the mortgage. Insufficient evidence of due diligence left the land attached and unavailable for auction, subject to a claim before the Special Court under section 8(8).

Capacity-based duty on pan masala packing machines depends on maximum operable packing speed rather than actual production speed. Where a twin-pack FFS machine is modified to pack a single product, the manufacturer's original speed quotation for the twin-pack configuration does not determine capacity after modification. In the absence of reliable material showing that the modified machine could not exceed the lower speed threshold, operation with a single product places it in the higher packing-speed category. Duty is consequently payable under the category for machines operating above that threshold.

Statutory appellate jurisdiction over refusal of court-ordered interim measures remains exclusively with the court designated under the Arbitration and Conciliation Act. An Arbitral Tribunal's power to grant interim measures cannot be converted into appellate jurisdiction over a court's interim-measure order, even with party consent. Accordingly, remitting a pending statutory appeal to a subsequently constituted Tribunal for treatment as an interim-measures application was set aside. Following the Tribunal's constitution, parties may independently seek legally available interim protection before it, while remaining disputes proceed to arbitration.

Rice bran oil and de-oiled rice bran produced through technical extraction and refining are manufactured commodities, not processed agricultural produce. The Schedule cannot expand the statutory definition of agricultural produce; executive inclusion of those products, consequential market-fee demands, and associated orders were invalid, with refund of paid fees directed. Market-fee amendments did not directly or immediately restrict movement of goods under Article 301 and did not require prior Presidential sanction. The special deemed-sale definition validly prevents fee evasion and is compatible with the Sale of Goods Act. Availability of market-wide regulatory services, rather than actual individual use, supports a fee levy on covered produce. Industrial and agricultural-market regulation operate in distinct fields, so no repugnancy arises.

Revisional jurisdiction over concurrent cheque-dishonour convictions is supervisory, not a second appellate review of evidence, and interference requires perversity, patent illegality, or miscarriage of justice. Admission of a signed cheque, including where it is alleged to have been delivered blank, triggers presumptions of consideration and legally enforceable liability; inconsistent or unsupported explanations do not establish a probable defence. Unchallenged bank evidence may prove dishonour, while a signed acknowledgement proves actual service of the statutory demand notice without recourse to deemed service. Custodial sentence and compensation may be sustained where they reflect the deterrent purpose of the offence and compensate for loss of use of funds and prosecution expenses.

IBC appellate review was sought against an NCLAT order. No good ground to interfere was found, so the civil appeal was dismissed and pending applications were disposed of. No substantive insolvency issue, statutory interpretation, or legal reasoning accompanies the refusal to interfere; the operative disposition is confined to dismissal of the challenge itself.

Section 34(2)'s one-year limitation for completing objection proceedings raises the question whether an uncompleted objection proceeding prevents enforcement of an assessment demand and requires refund of sums deposited by the dealer. The High Court issued notice and listed the matter for further hearing, without a recorded determination on enforceability of the demand or entitlement to refund.

Interest on delayed service-tax payment is ancillary to the principal tax liability rather than an independent levy. As no separate limitation is prescribed for interest, a demand must be raised within a reasonable period using the limitation framework for the principal demand under Section 73. Extended limitation requires allegations of fraud, collusion, wilful misstatement or suppression. Regular ST-3 filing and absence of such allegations confined the demand to the normal thirty-month period; the June 2020 notice for June 2017 was consequently time-barred and unsustainable.

Export duty liability was considered in relation to whether the declared FOB value should be treated as a cum-duty price and the consequent redetermination of duty. The appellant did not advance further arguments because the same issue had already been addressed in its own earlier appeal. The export-duty challenge was therefore dismissed.

FOB value of exported iron ore is the transaction value under the Export Valuation Rules, 2007, being the price actually paid or payable. It cannot be treated as a cum-duty price or reduced by the export-duty component when determining assessable value. Export duty must therefore be computed on the FOB transaction value without a notional cum-duty deduction, resolving the valuation issue against the assessee.

Section 69A treatment of loan receipts as unexplained money was unsustainable where the lender's PAN, confirmation, banking records of fund transfers, and GST records established identity, transaction genuineness, and creditworthiness. These materials demonstrated that the loan was received through banking channels and that the lender had the capacity to advance funds. The unexplained-money addition was consequently deleted because the available evidence did not support its retention.

Section 10(23C)(iiiad) exemption for an educational institution was not conditional, for assessment year 2017-18, on filing a timely return. Section 139(4C)(e) imposed a return-filing obligation but did not deny the exemption, and a belated return filed in response to a section 142(1) notice remained valid; the filing-linked restriction applied only from 1 April 2023. Cash deposited in specified bank notes during demonetisation was not unexplained money under section 69A where student-fee collections were supported by relevant fee receipts and no contrary material existed. The business-income and unexplained-money additions were deleted.

Section 271C of the Income-tax Act applies to failure to deduct tax at source and cannot, under strict construction of penal provisions, be extended to failure or delay in depositing tax already deducted into the Central Government account. Default in remitting deducted tax attracts separate statutory consequences, including interest under Section 201(1A) and prosecution under Section 276B. Penalty under Section 271C is therefore not leviable solely for non-deposit or belated deposit of tax already deducted at source, and the penalty was directed to be deleted.

Cash payments to group concerns against purchases recorded in a running account or against debit balances arising from sales do not constitute repayment of a loan or deposit for Section 269T purposes. A payment that did repay a loan through a running business account nevertheless fell outside the pre-amendment provision, which applied only to deposits; loans became covered from 1 June 2002. Section 269T was therefore not contravened, and penalty under Section 271E was not sustainable.

Employees' provident fund contributions for April and May 2020, deposited after the ordinary due dates during the COVID-19 lockdown, were treated as deductible under section 36(1)(va). The lockdown-related delay was accepted because the Employees' Provident Fund Organisation waived penal charges for that period, the amounts were deposited immediately after restrictions were relaxed, employees' funds were not retained for a prolonged period, and later deposits were timely. The resulting addition was deleted.

Comparable Uncontrolled Price analysis requires technology-knowhow royalty comparability to focus on the licence and knowhow transferred rather than product dissimilarity. Including non-exclusive agreements that meet the exclusivity criterion produced a median rate matching the royalty paid, eliminating the excess-royalty adjustment. Where a working-capital adjustment already captures delayed receivables and no interest is charged to unrelated parties, separate imputed interest on associated-enterprise receivables is unwarranted. Interest for delayed filing applies only when filing is late; advance-tax interest is consequential, while interest for instalment shortfalls is confined to returned income rather than assessed income.

Section 144 permits best-judgment assessment when a tax return, books, or material needed to determine taxable income are not produced. Where prior profitability lacks a consistent pattern and contemporaneous support for a lower estimate, non-compliance despite substantial business turnover can justify estimating business income at a net-profit rate applied to net bank deposits. Estimation at 0.5% of net bank deposits was treated as fair and reasonable.

Section 68 requires a taxpayer to establish the creditor's identity and creditworthiness and the genuineness of a credit transaction. Where identity is undisputed and bank records, capital-account entries and banking-channel transfers substantiate loans, the credits may not be treated as unexplained. Credits received in earlier years cannot be assessed as unexplained cash credits in a later relevant year. Salary expenditure for necessary part-time assistance may qualify as business expenditure where the payments are modest and genuine; absence of employee confirmation alone does not justify disallowance without material disputing business need or genuineness.

Loans supported by lender affidavits, confirmations, bank statements and source-of-funds records satisfied the requirements of identity, transaction genuineness and lender creditworthiness for Section 68 purposes. With no specific adverse findings in the remand report on these evidentiary elements, the short interval before loan repayment did not by itself discredit the transactions. The addition as unexplained cash credits was therefore deleted.

Cash deposits made during demonetisation and recorded as cash sales are not unexplained money where books of account, day-to-day stock records, cash book, sales ledger and accepted VAT returns trace the deposits to recorded sales. Section 69A requires a satisfactory explanation of the nature and source of money; where those records and explanations remain unrejected and free of identified infirmity, the evidentiary burden is discharged. Suspicion from unusual sales, specified bank notes, or a probability-based assessment cannot displace that documented explanation.