Timely payment under section 28(6)(i) statutorily concludes all matters stated in a customs show-cause notice, except proceedings expressly preserved. On that reading, proceedings concerning provisionally released imported goods cannot continue selectively for confiscation, redemption fine or penalty under section 114A after statutory conclusion. Redemption fine requires a valid confiscation order, while the proviso to section 125 regulates an existing confiscation power and cannot revive a power already brought to an end. Precedent concerning provisionally released goods does not determine the consequence of statutory conclusion under section 28(6)(i).

Confiscation in rem may validly apply to foreign-origin goods concealed in an import consignment that remain uncleared for home consumption, regardless of whether the named consignee qualifies as an importer. Personal penalties under sections 112(a) and 114AA require evidence that the consignee or partner ordered the goods, committed or abetted the offending act, or knowingly used a false declaration. Naming in a bill of lading alone does not establish importer status or knowledge. Untested witness statements and electronic correspondence lacking statutory proof cannot sustain penalties; confiscation remained valid while penalties were set aside.

Electric steering lock assemblies functioning solely as anti-theft immobilisers, rather than components transmitting or participating in steering movement, fall under CTH 8708 9900 as other motor-vehicle parts and accessories, not CTH 8708 9400. Reclassification requires cogent technical evidence, and AIS-075, HSN Explanatory Notes, or an earlier incorrect declaration cannot expand the narrower steering-system entry. Where goods are fully described and the dispute is a bona fide interpretative classification issue, no misdeclaration supports confiscation, no extended limitation applies absent fraud, suppression or wilful misstatement, and no penalty arises without culpable conduct. Redemption fine is unavailable where goods were already cleared for home consumption.

Alternative tariff classification raised in customs adjudication must be examined on merits, even if it falls outside the show-cause notice, because duty must be correctly assessed according to law. The alternative classification and related exemption claims were remanded for fresh adjudication for the normal period. Redemption fine cannot be imposed where goods cleared for home consumption are unavailable for confiscation, and the fine was set aside. Penalty under section 112 does not arise from a bona fide interpretational classification or exemption claim without misdeclaration, suppression, or deliberate duty-evasion conduct; the penalty was therefore set aside.

Co-accused statements and WhatsApp-chat material cannot support customs penalties where the statements lack independent corroboration, the makers are not cross-examined, and electronic data from a seized phone is not reliable or cogent. Penalties for assisting import of concealed prohibited or misdeclared goods require proof that the person knowingly abetted conduct rendering goods liable to confiscation. Penalties for false declarations additionally require knowing or intentional use of materially false documents. Without proof of knowledge, deliberate conduct, or false declaration, the penalties were set aside.

Duplicate customs duty payments compelled by a payment-portal error after the original duty liability is discharged constitute unauthorised excess collection, not customs duty. Accordingly, the statutory limitation for customs-duty refund claims does not govern recovery of the duplicate payment. A precedent involving valid tax payment followed by exemption is inapplicable. Setting aside the refund rejection permits the refund, while the connected recovery demand for an already sanctioned refund becomes infructuous.

Conditional exemption for parts used in solar photovoltaic modules is confined to parts consumed within the factory where those parts are produced. Imported or externally procured aluminium profiles remain outside the exemption even if fabricated elsewhere and ultimately used in module manufacture. Extended limitation for recovery of differential customs duty requires wilful misstatement or suppression of material facts; merely claiming a classification or exemption in a Bill of Entry does not establish suppression. Prior audits and earlier proceedings may also negate an allegation that material facts were withheld. Consequential interest and penalties depend on a sustainable, timely duty demand.

IGST exemption for aircraft parts re-imported after overseas repairs remains available under the re-import exemption framework. The later insertion of the words "tax and cess" and Explanation (d), used to support an IGST levy, was treated as ultra vires following its invalidation by the High Court. The associated circular cannot independently sustain IGST on repaired parts re-imported from abroad. Customs-duty exemption provisions therefore do not authorise IGST on eligible re-imported aircraft parts.

Motherboards imported without processors and RAM for assembly into an industrial computing platform are classified as parts of automatic data processing machines under Tariff Item 8473 30 20. Model-specific chassis designed solely or principally to house that platform's components are likewise classified as machine parts under Tariff Item 8473 30 99. AC-to-DC power supply units perform rectification and are independently classifiable as static converters under Tariff Item 8504 40 29, rather than as machine parts, because of their specific coverage in Chapter 85. Static converters designed for an automatic data processing machine may receive the applicable customs-duty exemption, subject to notification conditions, BIS certification, and import verification.

Regulation 38(3)(a) requires a resolution plan to identify and address the cause of default; merely describing losses, lack of turnover and excess liabilities does not satisfy that mandatory requirement. Non-compliance also breaches the statutory plan-scrutiny requirement and can justify rejection despite CoC approval. Protection for dissenting financial creditors extends to their minimum liquidation entitlement, not to a requirement that total plan value equal liquidation value. Investigation into the corporate debtor's affairs may be sustained where debt assignments during CIRP, voting control and plan deficiencies warrant inquiry. Premature limits on an assignee's distributable share should be removed pending investigation. Rectification or CIRP restoration before liquidation remains discretionary where defects are substantive rather than minor.

Section 44(1)(c) of the PMLA establishes a committal process for moving a scheduled-offence proceeding to the Special Court dealing with the associated money-laundering complaint when cognizance has been taken by different courts. An authorised PMLA authority cannot exercise its discretion in a manner that defeats this statutory scheme, while the court trying the scheduled offence retains responsibility for deciding the committal application. Under Article 226, a direction to initiate the committal process concerns an authority subject to writ jurisdiction rather than a judicial transfer of criminal proceedings. A sufficient territorial nexus may support such a direction even where the scheduled-offence proceeding is pending outside the State.

Attachment under the PMLA may extend to property held by persons not accused of the scheduled offence where it is linked to proceeds of crime; the objection based solely on lack of accusation was rejected. Cash deposits, seized currency and gold coins were treated as tainted assets because statements, deposit patterns and unexplained burnt currency connected them to embezzled funds, while the family-savings explanation was unsatisfactory. Those links also supplied sufficient reason to believe for the show-cause notice. Residential-property attachments were sustained because claimed legitimate sources were unsupported and loans did not explain the full consideration or tainted component. Proceeds of crime include the value of tainted property, permitting attachment of property of equivalent value.

Interim security for an invoice-based monetary claim pending arbitration may be warranted where objective material establishes a strong possibility that the respondent's assets will become insufficient or unavailable for execution. Proof of dishonest intention is not required. A prima facie claim may arise from invoices, correspondence, balance confirmation and payment assurances, while disputes over reconciliation, credit notes and a dishonoured cheque remain for arbitral determination. Audited financial deterioration, negative reserves, substantial liabilities, limited cash, encumbered assets and pending insolvency proceedings may support protective security. Security by deposit or an acceptable bank guarantee preserves the claim without constituting pre-award recovery or deciding liability.

Issuance of a cheque towards a time-barred debt may revive the debt and liability by acknowledgment. The time-barred nature of the underlying debt does not, by itself, prohibit issuing the cheque or bar prosecution for its dishonour under Section 138 of the Negotiable Instruments Act, 1881. An acquittal based solely on the debt being time-barred was set aside, and conviction for cheque dishonour followed.

The term sheet constituted a binding understanding, but completion of the share acquisition remained subject to due diligence, regulatory approvals, escrow arrangements, pre-conditions and definitive agreements. Funding obligations were stage-specific; loan advances did not prima facie constitute share-purchase consideration, and the purchaser had not shown timely payment of a material instalment or readiness to perform. Interim protection of escrowed shares was unavailable because the target company had requested status quo from the escrow agent, further securities and shareholder obligations remained disputed, and broader restraints would affect management. The Section 9 petition was dismissed, while preserving recourse to the arbitral tribunal for appropriate interim protection.

Under the Uttar Pradesh Value Added Tax Act, a railway container contractor's failure to disclose consignor and consignee particulars can sustain tax liability. Where materially identical facts are governed by an earlier binding ruling on the tax consequences of that non-disclosure, the same legal position applies. Non-disclosure of the relevant consignor and consignee details does not justify exoneration from VAT liability.

Penalties imposed solely on a person as a co-accused are unsustainable where the main proceedings against the principal accused have been remanded and penalties on similarly placed co-accused have been set aside. The person's liability arose only from co-accused status, and Revenue accepted that the person stood on the same footing as those granted penalty relief. The penalties therefore could not be sustained.

Under the Customs Act, 1962, issuance of a show cause notice for detained goods is an independent statutory requirement. A passenger's failure to attend appraisement cannot justify deferring or withholding that notice. Continued detention of seized goods without issuing the required show cause notice is contrary to law, irrespective of the passenger's nonappearance for appraisement.

Transit cargo routed through India to Nepal without crossing the customs barrier, being offloaded, or intended for domestic use does not constitute an import into India. Customs prohibitions and seizure powers applicable to importation or attempted importation therefore do not provide a jurisdictional basis for action against such cargo. Origin-based restrictions cannot apply where customs declarations, invoices, certificates of origin, transport documents and destination permits consistently establish Nigerian origin and Nepal as destination. Without verification under the prescribed origin-verification procedure, labels on only some bags cannot displace the official documentary record.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer has raised queries on alleged bogus purchases, considered the replies, and made an estimated addition on a legally plausible basis, revision cannot rest merely on perceived inadequacy of inquiry or disagreement with the percentage of addition. Requiring addition of the entire purchase amount in those circumstances substitutes the Principal Commissioner's view for the Assessing Officer's permissible view, leaving the assessment outside revisionary jurisdiction.