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.

Consistency with unreversed earlier decisions on identical facts and issues supports the same tax treatment in subsequent assessment years. This approach covers deletion of additions for unearned income; revenue deductibility of employee stock option expenditure; and non-sustainability of disallowances relating to overseas service-provider payments, networking and communication costs, legal and professional charges, and advertising, selling and marketing expenses. It also supports deletion of disallowance of the principal lease-rental component. Computer software falls within the computer block under New Appendix-1 from assessment year 2006-07, making it eligible for 40% depreciation rather than intangible-asset depreciation.

Bank records established that a loan transfer originated from the assessee's account and reached the actual recipient's account on the same date. An erroneous RTGS description had incorrectly reflected the transaction in the assessee's name. The documented debit and corresponding credit satisfactorily explained the loan source, rendering the unexplained-source addition unsustainable and resulting in its deletion.

Revisionary jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. A reassessment accepting nil returned income without examining substantial receipts shown as advances, despite tax deduction at source, may meet that standard. Necessary inquiry includes the character of receipts, their exclusion from the Income and Expenditure Account, their treatment as income or application of income, and the applicability of sections 11 and 13. Failure to conduct those inquiries, particularly where notice issuance was impeded by technical issues, supports revision of the reassessment order.

Additional receipts from flooring and furnishing work are characterised as business receipts, requiring estimation of taxable profit rather than assessment of the full gross receipt as undisclosed income. Taxable income from those receipts is estimated at 20%. Cash found during search is not fully assessable as unexplained merely because the cash book was not updated on the search date. Explanations based on cash withdrawals, existing cash-in-hand and trading receipts may be furnished during assessment, while a limited addition may be retained for any unexplained component.

Cash deposits in a bank account omitted from financial statements may be assessed as unexplained investment where the taxpayer fails to establish a credible source. Source evidence that does not withstand verification, including agreements containing dates inconsistent with the claimed transaction period, does not satisfactorily explain the deposits. Section 69 therefore applies to deposits for which no reliable explanation is proved.

Suppressed sales constitute turnover rather than income, so taxation is confined to the profit embedded in those sales. Where liquor stock is sold at discounted rates before licence expiry and variant-wise sales data are unavailable, profit may be estimated from purchase costs. A 3% profit rate on total purchase cost is treated as a reasonable basis for quantifying the taxable addition, rather than assessing the entire alleged suppressed-sales amount.

Section 263 revision cannot enlarge the matters available for examination in a limited-scrutiny assessment restricted to verification of cash-deposit sources. Interest-income discrepancies and possible deemed-dividend matters falling outside that scope cannot be introduced indirectly through revision. For issues within the stated scrutiny scope, revision requires an assessment that is both erroneous and prejudicial to Revenue interests. Verification of cash capital introduction by the Assessing Officer, supported by an unrebutted explanation that it represented a joint-venture member's contribution, does not meet that standard. The principles distinguish impermissible expansion of limited scrutiny from valid review of an inadequately examined in-scope issue.

The Finance Act, 2018 introduced a five per cent tolerance band for differences between sale consideration and stamp-duty value under the property-valuation deeming provisions in sections 43CA, 50C and 56. Treated as a beneficial, curative amendment, the tolerance band applies retrospectively to Assessment Year 2018-19. Accordingly, a variation below that threshold does not create deemed income under section 56(2)(x), preventing an addition based solely on the stamp-duty valuation difference.

Residual disallowance of purchases as bogus under Section 37(1) was unwarranted where invoices, lorry receipts, e-way bills, material receipt notes and bank-payment records supported the transactions. E-way bills and transport records evidenced movement and delivery of goods to the project site. Rough seized notings concerning estimated site expenses and an unrelated third party's statement did not displace the contemporaneous documentary evidence. As the purchases had been accepted as genuine for the full amount, the residual disallowance was deleted.

For unsecured loans assessed under section 68, creditor names, addresses, PANs, tax returns, audited accounts, loan confirmations, MCA records, bank statements and replies to section 133(6) notices support identity, creditworthiness and transaction genuineness. Accounting for interest with tax deduction at source and subsequent repayment further support the loan credits. Characterising creditors as shell entities alone, without contrary enquiry or material that discredits the evidence, does not justify treating documented loans as unexplained cash credits.

Renewal of charitable registration cannot be refused solely because a long-established educational institution lacks a formal trust deed or memorandum of association. Where a charitable trust was formed otherwise than under a written instrument, the relevant inquiry is whether available records adequately establish its creation and continuing charitable character. Public-trust registration, prior tax registrations, uninterrupted educational activity and contemporaneous records may provide that evidence. Consistent recognition of charitable status should not be displaced without a material change in facts or law, particularly where there is no adverse finding on objects, genuineness of activities, diversion of activities or legal compliance.