Property derived or obtained, directly or indirectly, from criminal activity relating to a scheduled offence, including its value, falls within proceeds of crime under the Prevention of Money Laundering Act, 2002. Registration of a scheduled offence alone does not establish that every asset is tainted; a cumulative money trail can establish a prima facie nexus. Bank-account analysis and statements linked project escrow funds to the property's acquisition. Independent business income, accounting disclosure, and partial funding from the project account did not break that nexus. The attachment therefore satisfied the reason-to-believe requirement and warranted confirmation.

Temporary protection from coercive action was limited to permitting petitioners to appear and have their statements recorded in a money-laundering investigation. The protection operated only until recording was completed, based on their undertaking to cooperate and the position that no coercive steps were then contemplated. It neither determined the allegations on their merits nor granted immunity from subsequent investigative action.

Regulation 27(1)'s qualifying conditions in clauses (i), (ii) and (iii) of sub-regulation (c) apply uniformly to borrowers, subsidiaries and associates of a credit rating agency's promoter under sub-regulations (a) and (b). Although the provision was ambiguous on their reach, a harmonious construction supports a common conflict-of-interest safeguard across all such promoter-linked entities. The interpretation is reinforced by the provision's purpose, contemporaneous regulatory materials, parliamentary discussion and the analogous wording of Regulation 28V. This construction prevents borrowers and subsidiaries from being excluded from the qualifying conditions applicable to associated entities.

Recall of a concluded intervention order requires proven fraud involving an intention to deceive and a material effect on the decision; an attested affidavit, where its contents are undisputed, does not meet that standard merely because it lacks a separate record of swearing. Curable affidavit irregularities do not vitiate adjudication, and recall cannot substitute for review on the merits. In disciplinary proceedings concerning a resolution professional, persons with only indirect interests arising from a separate liquidation lack the direct legal interest needed for impleadment or intervention. Limited participation under Order I Rule 8A is confined to public-interest legal submissions and cannot enable representative contest or entry solely through an interim stay application.

Separate corporate personality keeps a company's deposit obligations distinct from its directors' liabilities. A non-executive Chairman or Director does not become personally liable merely by holding office when deposits are accepted. Personal liability requires a personal guarantee, an independent contractual undertaking, statutory liability, or another recognised legal basis. As no such basis was established, the Chairman or Director bore no personal liability for repayment.

Advance rulings may cover ongoing imports where the goods are neither subject to a pending dispute nor already settled, with prospective operation. Pre-cut, non-rectangular, battery-specific die cut tape used principally for insulating and heat-protecting lithium-ion battery packs is classified as an other part of an electric accumulator under CTI 8507 90 90, rather than as a general-use plastic article. Continuous pressure-sensitive self-adhesive tape in rolls remains a general-use plastic article under heading 3919; rolls not exceeding 20 cm fall under CTI 3919 10 00, subject to dimensional verification. Both products are eligible for concessional basic customs duty when used in lithium-ion battery or battery-pack manufacture, subject to end-use and procedural requirements.

Storage-server classification under Heading 8471 turns on whether a model contains a central processing unit and system memory capable of automatic data-processing functions. CPU-less Crestone enclosures, being host-dependent devices that accept and deliver data, fall under tariff item 8471 70 90; CPU-integrated models are processing units combined with storage units under tariff item 8471 50 00, rather than units presented with input and output devices. Imported inputs used to manufacture all five servers qualify for the heading-level Basic Customs Duty end-use exemption if actually used in manufacture, excluding Chapter 74 goods and specified solar glass, and subject to concessional-duty procedures. The relief excludes integrated tax and other duties, taxes and cesses.

Car radio units designed for installation in motor vehicles, with AM/FM reception and integrated sound reproduction, fall within the specific tariff classification for motor-vehicle radio-broadcast receivers. Touchscreen, Bluetooth, Wi-Fi, USB, camera input, media playback and phone-mirroring functions remain integrated or ancillary features and do not alter that essential character. Where semi-knocked-down kits are imported together with the principal components and require only simple assembly, limited soldering, testing and configuration, they possess the essential character of the complete unit under Rule 2(a). Both completely built units and qualifying kits are classifiable under Customs Tariff Item 8527 21 00, subject to applicable BIS certification at import.

Refractories imported to re-line blast furnaces fall within the EPCG Scheme's capital-goods definition because they are accessories indirectly required to manufacture finished goods. The specific inclusion of refractories for initial furnace lining expands that definition and does not confine it to first installation or exclude replacement materials used in re-lining and maintenance. Such imports qualify for zero-duty treatment, leaving no basis for differential duty, interest, penalty, confiscation, or redemption fine.

Written acceptance of customs reassessment under Section 17(5) dispenses only with a speaking order; it does not waive the importer's statutory right to contest the reassessment or enhanced value. Rejection of declared transaction value under Section 14 and Rule 12(2) requires reasonable doubt about the declaration and written disclosure of the grounds before applying sequential valuation rules. NIDB or contemporaneous-import data and an acceptance letter alone, without independent cogent evidence, clear justification, and disclosure of relevant particulars, do not satisfy those procedural safeguards.

Customs valuation requires sustainable reasonable doubt before declared transaction value can be rejected, followed by sequential application of prescribed valuation rules to each import. Unverified mobile-phone records, selectively relied-on spreadsheets and invoices, uncorroborated statements, and extrapolation from other transactions do not provide reliable admissible grounds for undervaluation demands, particularly where contemporaneous-import data is disregarded. Accordingly, valuation-based differential duty, interest and penalties were unsustainable. Failure to authenticate certificates of origin justified denial of preferential tariff treatment, leaving duty and interest payable for affected imports; however, absent evidence of importers' knowledge, involvement or collusion, related penalties were unsustainable.

Rectification of a final customs order is confined to self-evident mistakes apparent from the record and cannot be used to rehear the appeal or adopt another possible view. Challenges to a penalty based on the furnishing of non-transferable licences, end-use bonds and bank guarantees-including objections on importer status, misdeclaration, show-cause notice scope and the applicability of the penal provision-require fresh examination of evidence and legal consequences. Such challenges concern the correctness of the concluded penalty finding and must be pursued through appellate review rather than rectification.

Cash is movable property under the Prohibition of Benami Property Transactions Act, 1988. Where a person receives cash from its beneficial owner, deposits it into a proprietorship account in that person's name, and retransfers it for the owner's benefit, the arrangement can meet the statutory elements of a benami transaction: the recipient is a benamidar, and cash may operate as both property and consideration. Immediate banking retransfer following attempted demonetised-cash conversion does not by itself remove the arrangement from the statutory definition. Attachment must account for tax paid and sums placed in interest-free disclosure bonds.

Limitation for final assessments under the DRP mechanism is governed by a harmonious reading of Sections 144C and 153: the outer period in Section 153 continues to apply, while Section 144C(13) requires prompt completion after DRP directions without overriding that deadline. An interim restraint concerning a different High Court ruling did not prevent reliance on an unstayed binding ruling; Section 158AB provides the Revenue a mechanism where the same legal question is pending before the Supreme Court. The assessment made after expiry of the statutory deadline was quashed, subject to possible revival following the Larger Bench ruling.

Reassessment for AY 2019-20 under the post-Finance Act 2021 framework was examined against the limitation in section 149(1). Where alleged escaped income is below the threshold for the extended limitation period under section 149(1)(b), a notice under section 148 must be issued within three years from the end of the relevant assessment year. That period expired on 31 March 2023. A notice issued on 12 April 2023 was beyond time, and no additional period was available for the section 148A procedure in a search-information matter; the reassessment lacked jurisdiction.

Section 12AA(3) permits cancellation of charitable registration only where activities are non-genuine or depart from the trust's stated objects. Alleged capitation fees based on inconsistent third-party loose sheets and statements, without corroboration from parents, students, institutional records, unexplained cash, or evidence of diversion, do not by themselves establish institutional non-genuineness. Isolated receipt-related allegations may instead be examined in assessment proceedings, including any denial of exemption where legally justified. An inherent-jurisdiction objection remains maintainable despite prior non-objection because consent, acquiescence, or waiver cannot confer jurisdiction; the underlying validity of the asserted jurisdiction requires separate adjudication.

De novo reassessment of an assessment completed under section 143(3) must be limited to the specific unsecured loans requiring examination. Where replies and supporting material were furnished, adverse inference related only to identified loans, and other loans were accepted, an appellate remand requires a rational nexus with the disputed issue. Reconsideration should not unsettle accepted findings without adverse material or findings against them. The remand is therefore confined to examination of the disputed unsecured loans, while accepted findings on the remaining loans remain undisturbed.

Search-based additions require corroborative evidence where a section 132(4) surrender is credibly reconciled; unsupported loose sheets and arbitrary commission extrapolation cannot alone establish undisclosed income or expenditure. Assessments of completed years under section 153A may proceed where search yields incriminating material. No section 14A disallowance arises without exempt income for the relevant year, and the 2022 Explanation is prospective. Depreciation on own-use trucks is calculated at 15% on correctly recomputed written-down value; section 35D capital employed excludes share premium but includes qualifying borrowings. Delayed-TDS interest is deductible as compensatory business expenditure. Salary, GDR expenditure and partnership-investment issues require evidence-based verification.

Section 50C(2) provides a statutory valuation mechanism where the stamp-valuation figure is claimed to exceed fair market value and prescribed conditions are met. Short-term capital gains require fresh determination after examining acquisition cost, acquisition date and relevant transaction records, which had not been examined. Where warranted, a reference to the Departmental Valuation Officer should be made and any valuation report considered. The computation must be redetermined after providing an effective opportunity of hearing, without expressing a view on its merits.

Transfer-pricing comparability for captive, limited-risk software-development service providers requires alignment of functions, assets and risks under FAR analysis. Diversified companies owning substantial brands, goodwill, patents and other intangibles, incurring significant research and development expenditure, and assuming substantial business and intellectual-property risks are materially different from cost-plus captive providers. Where standalone segmental information for comparable service activities is unavailable, such companies should be excluded from the comparable set. The transfer-pricing adjustment requires recomputation using functionally comparable entities.