PMLA treats assets disproportionate to known income under the scheduled offence of disproportionate assets as proceeds of crime where they are possessed, acquired, concealed, used, or projected as untainted property; a separate bribery allegation is not required. Attachment may be confined to the quantified disproportionate assets after accounting for known income, loans and expenditure, including property linked to a spouse where an independent lawful source is not established. Provisional attachment requires a predicate offence and grounds indicating likely alienation; an unsupported assertion of prior investigating-agency attachment does not invalidate it. Challenges to findings on cash deposits require supporting bank statements or other documentary material.

Section 7 admission requires proof of financial debt and default exceeding the applicable statutory threshold; disputes over exact dues or contractual interest need not be resolved at the admission stage where debt and default are admitted. CIRP is not barred by Section 10A where the default arose before, or continued beyond, the protected period, including where the recorded default falls outside that period. A partial payment or settlement offer does not justify interference with admission when it is substantially below the creditor's claim and has not been accepted. Accordingly, established debt, qualifying default and unmet statutory conditions support commencement of CIRP.

Section 96(4) of the Insolvency and Bankruptcy Code applies to pending insolvency applications against personal guarantors to corporate debtors. Inserted to prevent misuse of the interim moratorium for obstructing creditor recovery, the provision operates prospectively on the continuing status of applications pending on its effective date, with quasi-retroactive effect. The phrase "is filed" includes applications filed before the amendment that remained pending. Vacating pre-admission protection does not impair a vested right; it restores creditors' ability to pursue remedies during the pending insolvency process. Consequently, the interim moratorium ceases from the amendment's effective date and does not bar the suit.

A 42-day delay in filing a company appeal was condoned because the materials on record justified hearing the appeal on merits. The appeal was restored to the High Court for decision in accordance with law.

Advance rulings cannot be issued where an identical classification question has already been decided by a court; accordingly, the request concerning roasted areca nuts was barred under the Customs Act. Roasted walnuts, having undergone high-temperature roasting that alters their flavour, colour and texture for immediate consumption, fall within the specific tariff coverage for dry-roasted or fat-roasted nuts under Heading 2008 rather than Chapter 8 for fresh or dried nuts. Concessional customs duty is available only where the importer strictly establishes compliance with the applicable notification and prescribed country-of-origin requirements to the competent customs officer's satisfaction.

Veterinary active pharmaceutical ingredients with established therapeutic use, including Clopidol (VET) and Amprolium 100% (VET), fall within the inclusive statutory meaning of drugs because it covers animal medicines and substances used as drug components. The specific IGST rate entry for all drugs and medicines is description-based, applies to goods classified under Chapter 30 or other chapters, and is not limited to finished dosage forms. It therefore takes precedence over the general organic-chemical entry for such veterinary APIs. The products qualify for the concessional IGST rate, provided they are not covered by the separate nil-rate entry for specified drugs.

Roasted walnuts fall under Tariff Item 2008 19 91 as other roasted nuts and seeds because roasting is a high-heat process distinct from drying and is not among the processes covered by Chapter 8. Classification follows Rule 1 of the General Rules for Interpretation, the relevant tariff headings and notes, supported by HSN Explanatory Notes and trade understanding. Preferential basic customs-duty treatment under the notified ASEAN-India arrangement is available only where the importer satisfactorily establishes that the goods originate in the relevant notified country under the applicable origin rules and the Customs Rules of Origin framework.

Declared transaction value for imported cigarettes cannot be rejected or enhanced merely on unauthenticated certificates of origin and purported export shipping bills. A valid overseas supply contract supported the declared value, while no evidence established additional payment, misclassification, or higher-priced comparable imports. The certificate was neither used for preferential treatment nor officially verified, and third-party shipping bills were not shown to be authentic or to reflect the true import price. Uncorroborated statements acknowledging those documents were insufficient without admissible supporting evidence. In the absence of reliable contemporaneous import evidence or cogent valuation material, the undervaluation allegation fails.

Penalty under Section 112(b) requires proof that the person knew the imported goods were offending goods. Uncorroborated customs broker statements, a non-inculpatory statement by the person penalised, and the absence of evidence from the person seeking temporary storage did not establish that knowledge. Although the imported goods were stored other than at the designated place without informing customs authorities, that breach did not satisfy the knowledge requirement for Section 112(b). The conduct instead attracted the residual penalty under Section 117 for failure to comply with storage-related customs requirements.

Preferential customs-duty benefits require Customs to follow the prescribed verification process before rejecting a Certificate of Origin. Where Customs doubts a certificate, it must communicate the grounds to the issuing authority and obtain clarification through specific, time-bound verification. General communications concerning other certificates or importers do not establish that an importer's certificate is non-authentic. Documentary certificates cannot be displaced by assumptions about a supplier's business profile, unverified electronic communications, or third-party statements. Retracted and uncorroborated statements, particularly where not tested through examination and cross-examination, cannot substitute for verification. Failure to undertake certificate-specific verification renders denial of preferential duty and consequential recovery, confiscation, fine and penalties unsustainable.

Keyboards imported through courier for personal use remain classifiable under Customs Tariff Heading 8471 60 40 where that specific entry carries a free rate of duty. Chapter 98 overrides a specific tariff heading only when its conditions are met. Heading 9804 and the corresponding Schedule IV IGST entry apply only to dutiable goods imported for personal use; goods attracting no duty under their applicable tariff entry are not dutiable goods. Consequently, keyboards covered by the free-rate Heading 8471 60 40 cannot be reclassified under Heading 9804, and customs duty or IGST under that personal-import entry does not apply.

Aluminium hollow profiles retain classification under the specific tariff heading for aluminium profiles where their objective characteristics, including uniform cross-section, remain intact at import. Cutting profiles to length, invoice descriptions, prior self-assessment and intended use in solar modules do not by themselves convert them into finished articles or justify classification under a residuary heading. Concessional customs treatment for Chapter 76 goods used to manufacture notified Solar PV Modules depends on the prescribed end-use procedure and valid end-use certificates, rather than possible alternative uses or precise classification within that Chapter. The stated amendment applies prospectively from 1 April 2022; concessional treatment remains available for earlier Bills of Entry meeting the conditions.

Redemption of confiscated foreign currency under Section 125 of the Customs Act is discretionary where the currency was exported without declaration or required permission and may be treated as prohibited goods. That discretion must be exercised judiciously on the facts, rather than refused mechanically because the goods are prohibited. Relevant considerations include the absence of earlier Customs Act violations, payment of penalty, the statutory limit on redemption fine, and consistency with comparable cases. Refusal of redemption was set aside, requiring release of the currency upon payment of a redemption fine determined under Section 125.

Retrospective amendments to the Foreign Trade Policy cannot extinguish Service Exports from India Scheme benefits accrued by exporters for eligible services already rendered and foreign exchange already earned. Section 5 of the Foreign Trade (Development and Regulation) Act, 1992 permits formulation and amendment of the policy but does not authorise retrospective curtailment of accrued scheme entitlements. Notifications introducing Appendix 3X, excluding specified services and imposing a cap for FY 2019-20 operate only from their respective issue dates. Exporters remain entitled to SEIS benefits accrued during the relevant pre-notification period.

Benami classification under Section 2(9)(C) requires that the ostensible owner be unaware of, or deny knowledge of, the property ownership. Job workers acknowledged during cross-examination that they knew of the share allotment, buy-back and consideration credited to their bank accounts. These statements outweighed inconsistent earlier income-tax statements. Allegations of fictitious trade payables or tax evasion could not independently establish a benami transaction without satisfying the statutory knowledge requirement. The income-tax settlement order did not override the separate benami regime. The share transactions therefore fell outside Section 2(9)(C), and refusal to confirm provisional attachment was sustained.

Tax deduction under section 194LBC applies only to income payable to an investor in respect of that investor's investment in a securitisation trust. Excess Interest Spread paid to an originator that neither subscribed to pass-through certificates nor otherwise invested in the trust does not meet those conditions. Maintaining the minimum retention requirement through cash collateral does not make the originator an investor for this purpose. As the payment represents residual surplus under the transaction waterfall rather than income from an investment, no tax is deductible under section 194LBC, and default consequences under sections 201(1) and 201(1A) do not arise.

Interest awarded under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsorily acquired land is treated as an accretion to the land's value and forms part of enhanced compensation. It differs from interest under Section 34, which compensates for delayed payment. Income-tax amendments governing interest on compensation address the timing of taxation of interest income and do not change the character of Section 28 interest. Accordingly, Section 28 interest is not assessable under the head Income from Other Sources.

Notice under Section 143(2) is not required for reassessment where no valid return is filed under Section 139 or in response to a notice under Section 148. Exemption under Section 10(26) applies only to qualifying income computed under the Act, not to gross receipts or bank deposits; tribal status, residence documentation and GST registration alone do not establish eligible business income. Cash deposits may be assessed as unexplained money under Section 69A where the taxpayer fails to substantiate their nature and source with reliable business records, books of account, bills, vouchers or financial statements.

Foreign-currency loans to associated enterprises may be benchmarked under the Comparable Uncontrolled Price method using foreign lending rates and external comparable borrowings; a domestic cost-of-funds approach is not a comparable uncontrolled price for an international loan. Interest charged at LIBOR plus 350 basis points was treated as arm's length. A standby letter of credit for an associated enterprise's borrowing requires arm's length benchmarking, with the corporate-guarantee benchmark restricted to 0.5% absent material supporting a higher fee. Weighted deduction for eligible expenditure on a DSIR-approved in-house research and development facility is not limited to the amount quantified in Form 3CL.

Transactional net margin method comparables for captive data-processing and software-development services must be functionally and economically similar. Rule 10B(4) permits use of data from the two preceding years; a company is not a persistent loss-maker merely because it incurred losses in some relevant years, and a differing accounting year alone does not require exclusion where quarterly data can be extrapolated. Companies with materially different business models, substantial outsourcing, high-end services, software products, diversified licensing activities, significant brands or intangibles, entrepreneurial scale, or unreliable segmental data should be excluded. Repair and maintenance provisions require verification of supporting evidence, subsequent crystallisation and reversal, consistent with DRP directions.