An approved resolution plan binds all creditors, including those who did not file claims, and extinguishes claims that are not included in the plan. Continuing execution proceedings based on a pre-approval money decree would undermine the insolvency resolution framework. Deposit of the decretal amount is not invariably required to obtain a stay of a money decree where exceptional circumstances exist. The binding effect of the approved resolution plan and the statutory consequences of Section 31 constitute such circumstances, supporting a stay of the decree's operation, execution and implementation pending final disposal of the appeal.

Criminal liability of a statutory auditor for account-related defaults requires the statutory status or specific management charge contemplated by the relevant provisions; an auditor outside those categories cannot be prosecuted for non-compliance concerning the company's accounts. False-statement liability requires a knowingly material false statement or omission, and cannot rest merely on failure to report accounting-standard non-compliance. Penal liability for audit-reporting failures further requires a pleaded and supportable wilful default; qualifications in audit reports and alleged inadequate enquiries may indicate lack of due care but do not establish wilfulness. The proceedings were therefore unsustainable on the pleaded allegations.

Police assistance for eviction or securing possession cannot be used while a purchaser's application for vacant possession remains pending before the Company Court, unless the Company Judge directs otherwise. The pending application must receive expeditious consideration. The directions preserve the Company Court's control over possession and prevent police-assisted eviction without its express order.

Confiscation of gold brought into India as baggage falls within the statutory exclusion from the Tribunal's appellate jurisdiction. Appeals concerning such baggage matters cannot be pursued before the Tribunal; the prescribed remedy is revision before the Revisionary Authority of the Government of India. The jurisdictional bar determines the appropriate forum for challenging the confiscation order.

Departmental appeals involving anti-dumping duty are subject to the prescribed monetary threshold under the Government litigation policy. Where the duty involved falls below that threshold, the Revenue's appeal is not pursued and is dismissed; the related cross-objection is disposed of accordingly.

Absolute confiscation applied to gold recovered from conscious possession because, as notified goods, the statutory burden to prove lawful importation, acquisition or possession was not discharged; the gold was confiscated under the Customs Act. Indian currency was confiscated as sale proceeds of smuggled gold where records, statements and unexplained possession linked it to bullion dealings. Penalty was sustained against the person knowingly involved in transporting and dealing with smuggled gold, supported by recovery, statements and transaction records. Penalties against a family member and an employee were set aside because relationship or employment, without cogent corroborative evidence of conscious and active participation, does not establish abetment or dealing with confiscable goods.

Derivative penal liability for abetment under the Customs Act cannot survive where the principal allegation against the importer fails. The imported components, without an electric motor and battery, did not have the essential character of complete electrical tricycles under Rule 2(a) of the General Rules for Interpretation. They were correctly declared as parts/components, and the classification dispute involved no misdeclaration. As confiscation, differential duty and penalties against the importer were unsustainable, no underlying contravention remained to support a penalty against the alleged abettor. The penalty was therefore set aside.

Customs Broker licence revocation requires a valid offence report under the Customs Brokers Licensing Regulations, 2018; proceedings founded only on findings in the exporter's separate adjudication are unsustainable. A Customs Broker processing exports later alleged to be overvalued does not breach its regulatory obligations without evidence of knowledge, connivance, or involvement. Compliance with KYC requirements, reliance on apparently genuine client and government-issued documents, and filing shipping bills assessed and cleared by Customs support absence of breach. The Broker is not required to independently investigate export valuation where documents appear authentic. Revocation, security forfeiture, and penalty lack legal basis where statutory initiation requirements and a proven regulatory breach are absent.

Penalties for aiding and abetting customs-duty evasion under Section 112(a)(ii) require evidence that the Customs Broker and its G-Card holder had prior knowledge of the importer's misdeclaration and materially assisted it. Processing import documents and filing Bills of Entry based on documents supplied by the importer, without corroborative evidence of knowledge of quantity misdeclaration or participation in duty evasion, does not establish aiding or abetting. On the stated analysis, the penalties were unsustainable and set aside.

Unsecured loans and corresponding interest could not be treated as unexplained where the assessee produced lender confirmations, tax returns, bank statements, ledger accounts and financial statements. The material established lender identity, financial capacity and transaction genuineness, with loans routed through banking channels and interest paid after tax deduction at source. The Department did not disprove this evidence or substantiate allegations that lenders' sources were non-genuine. Selective additions were also inconsistent with acceptance of most of the same loan transactions. For the relevant years, the assessee was not required to prove the source of lenders' funds. The loan and interest additions were therefore deleted.

Reassessment based solely on an Insight Portal chart, without the Assessing Officer obtaining, examining, or identifying underlying seized material linking the assessee to alleged cash payment, lacks a rational nexus with escaped income and reflects borrowed satisfaction; the Section 148 notice was therefore invalid. An addition for alleged on-money payment cannot rest on incomplete, unproduced and uncorroborated material that neither identifies the assessee nor establishes cash payment or connection with the purchased property; the Section 69 addition was unsustainable and deleted. Independent application of mind to material with a live link to escapement is required for reassessment.

Under the post-1 April 2021 reassessment regime, prior approval for a reassessment notice depends on the time elapsed from the end of the relevant assessment year. Once more than three years have elapsed, Section 151 requires sanction from the prescribed higher specified authority rather than a Principal Commissioner. Approval by an authority lacking that prescribed competence renders the reassessment notice invalid and undermines the consequential reassessment proceedings.

Estimated chit subscriptions cannot be treated as unexplained investment under Section 69 merely by averaging aggregate chit dealings across years. Where impounded material records liabilities rather than a specific unrecorded investment in the relevant year, and bid receipts and borrowings explain instalment funding, the addition is unsustainable. Likewise, estimated interest cannot be assessed as unexplained expenditure under Section 69C through mathematical allocation of an aggregate amount without year-specific evidence of actual payment. Continuing borrowings and upfront interest deductions from loan disbursements provide an identifiable source. Broad admissions without transaction-specific corroboration cannot alone sustain such additions.

For capital introduced by a partner, the firm established the contributor's identity, capacity and the genuineness of the remittances through recorded direct transfers, payments to land vendors, a registered sale deed and assessment of the sale consideration as capital gains in the partner's own case. The capital computation also required exclusion of opening capital, credited profit and remuneration. Where the partner admits and substantiates the contribution, a separate question concerning the partner's source does not, on the established facts, justify treating the amount as unexplained cash credit in the firm's hands.

Tax-deduction disallowance of residual consultancy charges remained sustainable because the supporting material did not show that the amount fell outside the withholding obligation, while substantiated service-tax relief was retained. Interest disallowance was sustained for one payee lacking compliance evidence and remitted for verification for another payee. Expenses crystallising during the relevant year, including invoices issued to an affiliated entity on identical facts, were treated as allowable; prior-period treatment was revenue neutral. Written-off balances, though not allowable as bad debts, qualified as business expenditure or business loss. Customer advances were not unexplained cash credits where identity, genuineness and creditworthiness were established. No disallowance under section 14A and rule 8D applied absent exempt income; deletions of prior-period and business electricity expenses were retained.

Reassessment notices for assessment years 2013-14 and 2014-15 were issued after the applicable limitation period expired. After accounting for the surviving limitation period and the statutory minimum period following the assessee's response to show-cause notices, the deadline ended on 16 June 2022. Notices issued under Section 148 in late July 2022 were therefore time-barred. The amended reassessment regime and relaxation legislation did not preserve the Revenue's authority to issue notices after expiry of that limitation. Consequently, the reassessment proceedings based on those notices were void and quashed.

Reassessment under Section 147 requires recorded reasons based on tangible material identifying the alleged accommodation-entry entities and transactions. General information, unsupported by credible material, cannot justify reopening where statutory notices, approval material and the assessment order omit the relevant entities. Bank records and audited financial statements showing no transactions, borrowings or repayments with those entities further negate the alleged basis for reassessment. The reassessment proceedings and consequential assessment were therefore void ab initio and quashed.

Income recognised on accrual basis for completed consultancy services cannot be taxed again merely because the related tax deduction appears in Form 26AS in a later year; the timing of tax deduction does not override income recognition. Transfer charges and commission directly connected with sale of property are deductible when computing capital gains, even if not allowable as business expenditure. Professional fees for arranging working-capital funding require adequate proof of business utility and substantiation; where these are incomplete, proportionate disallowance may apply. The discussion treats the Form 26AS mismatch addition as unsustainable, allows property-transfer expenses under capital gains, and supports partial disallowance of inadequately supported funding consultancy fees.

Business-promotion expenses were treated as business-related but only partly substantiated, resulting in restricted disallowance. Letter-of-credit charges and software-development expenditure were treated as allowable because partial capitalisation lacked a sustainable basis and a one-time payment alone did not establish capital character. Foreign-exchange loss, fixed-deposit interest additions, unsupported expenditure, gratuity provision and tax-payment claims remained disallowed for lack of reconciliations, accounts, supporting particulars or proof of payment. Ad hoc disallowances for engineering stores and printing and stationery were reduced as the original rate was excessive. Taxable income requires recomputation after giving effect to deleted, restricted and sustained disallowances.

A notice under Section 148 for Assessment Year 2015-16 was beyond the limitation period applicable under the pre-amendment regime, which expired on 31 March 2022. The first proviso to Section 149(1), inserted by the Finance Act, 2021, preserves that restriction for past assessment years. The fifth and sixth provisos, which provide exclusion and extension mechanisms within the amended three-year or ten-year framework, cannot extend the limitation preserved by the first proviso. Consequently, the notice dated 7 April 2022 was time-barred, invalid, and incapable of conferring jurisdiction for reassessment.