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2026 Supreme(Online)(ATFP) 64

APPELLATE TRIBUNAL FOR FORFEITED PROPERTY
MUNISHWAR NATH BHANDARI, Chairman, G. C. MISHRA, Member
M/s Pawan Finvest Pvt. Ltd. – Appellant
Versus
The Deputy Director, Directorate of Enforcement, Hyderabad – Respondent


Advocates:
For the Appellant: Mr. Abhinav Raj, Adv., Mr. Ayush Raurav, Adv., Mr. Vinayak Trivedi, Adv., Mr. Abhinav Sekhri, Adv., Ms. Shalanki Prasad, Adv.
For the Respondent: Ms. Anubha Bhardwaj, Adv.

Table of Content
1. overview of the illegal lending operations (Para 2 , 3 , 4 , 5 , 6 , 7)
2. appellants' claims of compliance with rbi guidelines (Para 10 , 11 , 15 , 28)
3. details on the involvement of fintech companies and nbfcs (Para 19 , 20 , 21 , 22 , 23)
4. arguments regarding regulatory violations and customer harassment (Para 25 , 26 , 29 , 30 , 31)
5. final dismissal of the appeals (Para 36)

ORDER

05.01.2026

The batch of appeals have been filed under Section 26 of the Prevention of Money Laundering Act, 2002 (‘the Act of 2002’) challenging the order dated 27.01.2023 passed by the Adjudicating authority confirming the provisional attachment order. The impugned order was passed against defendants before the Adjudicating Authority however the appeal has been filed by the appellants companies before us and accordingly, we would be dealing with the issues raised by it.

Brief facts of the case:

2. It is a case where 43 FIRs have been registered for the offences under the Indian Penal Code,1860 and Information Technology Act, 2000 (in short, the ‘the Act of 2000’). The Cybercrime PS, Rachakonda had registered 5 FIRs for offence under section 417, 419, 420 of the Indian Penal Code, 1

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