Issues: (i) Whether the final assessment orders passed under section 144C(13) read with section 153 of the Income-tax Act, 1961 are time-barred and, if so, whether such orders are without jurisdiction and liable to be quashed.

Analysis: The issue requires examination of the statutory timelines in section 144C and section 153 and their interplay where DRP proceedings are invoked. Section 144C provides a multi-stage mechanism with specified time windows for draft order, filing objections, DRP directions and passing of the final order; section 153 prescribes outer time limits for completion of assessment proceedings, including on remand. The reasoning in the cited authority adopts a construction that the timelines under section 153 continue to apply when proceedings are remitted (or continued) under section 144C, making the provisions mutually inclusive rather than mutually exclusive. Application of those principles to the undisputed date chart shows that the final orders were passed after the outer limitation dates calculated with reference to section 144C read with section 153.

Conclusion: The final assessment orders passed beyond the period of limitation under section 144C(13) read with section 153 are without jurisdiction and are quashed; outcome is in favour of the assessee.

Issues: Whether the final assessment orders passed after completion of DRP proceedings under section 144C(13) are barred by limitation and therefore without jurisdiction, having regard to the interplay between section 144C and section 153 of the Income-tax Act, 1961.

Analysis: The Tribunal examined whether section 144C constitutes a self-contained code that excludes the time-limits in section 153 or whether the timelines under section 153 operate as an outer limit applicable on remand/DRP proceedings. The Tribunal considered the Madras High Court decision in Roca Bathroom Products P. Ltd., which held that sections 144C and 153 are mutually inclusive and that the outer time limits in section 153 (including section 153(2A)/(3)/(4) as applicable) govern remand/DRP proceedings; it noted the statutory timelines within section 144C (including provisions for draft order, filing of objections, DRP directions and finalisation) and the non-obstante language, but followed the reasoning that DRP proceedings form continuation of assessment and must be completed within the outer limitation prescribed under section 153. The Tribunal also addressed and rejected the Revenue's contention to defer hearing because of pending references in the Supreme Court, andon the meritsfound that the dates in the appeals showed final orders were passed beyond the applicable limitation period determined with reference to section 144C read with section 153.

Conclusion: The final assessment orders passed beyond the period of limitation calculated with reference to section 144C read with section 153 are without jurisdiction and are quashed; the appeals are allowed in favour of the assessee.

Issues: Whether retention of property under the Prevention of Money Laundering Act without a prior order under Section 20 and without compliance with the statutory safeguards could be sustained.

Analysis: The statutory scheme requires a fresh and independent recorded reason to believe for retention after seizure, forwarding of the retention order and material to the Adjudicating Authority, adherence to the 180-day period, and the Adjudicating Authority's satisfaction regarding prima facie involvement in money laundering. Section 20 operates as a mandatory safeguard and a necessary precondition to invocation of the confirmation mechanism under Section 8(3). Direct resort to adjudication without compliance with Section 20 bypasses the prescribed manner of action and renders the retention legally unsustainable. Continued deprivation of property in the absence of such compliance also infringes the constitutional protection of property.

Conclusion: Retention of the property without an order under Section 20 was invalid and could not be sustained.

Issues: Whether the CESTAT was correct in holding that the refund claim of cenvat credit pertaining to deemed export of goods under Rule 5 of the Cenvat Credit Rules for the quarter October to December, 2009 is hit by the bar of limitation under Section 11B of the Central Excise Act, 1944.

Analysis: Section 11B prescribes a one year period from the relevant date to apply for refund. The statutory explanations to Section 11B do not specifically cover supplies between 100% EOUs in the facts of this case. The refund procedure under the applicable notification (dated 01.03.2002) allowed EOUs to claim refund with reference to calendar periods, thereby making the relevant date referable to the last day of the period/quarter for which refund is claimed. Applying that framework, the relevant date for the quarter OctoberDecember 2009 is 31.12.2009; the one year limitation under Section 11B therefore expired on 31.12.2010 while the application was filed in March 2011.

Conclusion: The refund claim for the quarter October to December, 2009 is barred by limitation under Section 11B of the Central Excise Act, 1944; the appeal is dismissed (decision in favour of Revenue).

Issues: Whether the Special Leave Petition should be entertained despite a delay of 676 days and whether interference with the High Court's order is warranted on merits.

Analysis: The Court noted a gross unexplained delay of 676 days in filing the Special Leave Petition and examined whether such delay could be condoned. Independently, the Court considered the merits of the challenge to the High Court's order and found no reason to interfere. The combined effect of the unexplained delay and absence of merit led the Court to refuse relief.

Conclusion: The Special Leave Petition is dismissed on the grounds of delay and on merits; decision is in favour of the Respondent.

Outcome: Special Leave Petition dismissed on the ground of delay and on merits, with the question of law kept open.

Issues: Whether anticipatory bail ought to be granted to the applicant in respect of offences under the Chhattisgarh Goods and Services Tax Act, 2017.

Analysis: The allegation was of evasion under Section 132 of the Chhattisgarh Goods and Services Tax Act, 2017. The material placed before the Court indicated that the offence was not punishable with death or life imprisonment and that the maximum sentence prescribed was five years. The applicant was found to have cooperated with the investigation, and the Court found no likelihood of tampering with evidence or influencing witnesses. The applicant's readiness to comply with conditions, including furnishing bond and appearing as required, was also taken into account.

Conclusion: Anticipatory bail was granted to the applicant.

Issues: (i) Whether imposition of penalty under section 271AAC(1) read with section 274 of the Income-tax Act, 1961 is maintainable while the assessee's quantum appeal raising a substantial question of law is pending disposal before the High Court; (ii) Whether the penalty order is invalid on the ground that penalty proceedings were initiated without recording a valid satisfaction as required.

Issue (i): Whether imposition of penalty under section 271AAC(1) r/w section 274 is maintainable pending disposal of a substantial question of law admitted by the High Court.

Analysis: The Tribunal noted that the High Court of Delhi has admitted a substantial question of law in the assessee's quantum appeal (order dated 27.03.2025) covering relevant assessment years. The Tribunal treated the admission of the substantial question as making the imposition of penalty debatable and recognised the pendency of the High Court proceeding as material to the appropriateness of continuing with penalty adjudication at this stage. The Tribunal considered the parties' requests and the departmental representative's suggestion to keep the appeal pending until the High Court decision.

Conclusion: The Tribunal set aside the penalty order and the appellate order upholding it, holding that imposition of penalty is not maintainable at this stage and directing that the Assessing Officer may initiate penalty proceedings after the substantial question of law is decided by the High Court. The conclusion is in favour of the assessee.

Issue (ii): Whether the penalty order is invalid for lack of recorded satisfaction prerequisite to initiation of penalty proceedings under section 271AAC(1) r/w section 274.

Analysis: The Tribunal recorded the assessee's contention that initiation of penalty proceedings required recording of a valid satisfaction, which was alleged to be absent. While noting this ground, the Tribunal's operative decision was driven by the pendency of the substantial question of law before the High Court and the debatable nature of the penalty; the Tribunal therefore set aside the penalty order without finally adjudicating the correctness of the recorded satisfaction issue, leaving the Assessing Officer liberty to proceed afresh after the High Court decision.

Conclusion: The Tribunal did not uphold the penalty; it set aside the penalty order and appellate order without making a final finding on the recorded-satisfaction point. The practical effect is favourable to the assessee.

Final Conclusion: The appeal is allowed and both the Assessing Officer's penalty order dated 29.11.2023 and the Commissioner (Appeals)' order dated 13.06.2025 are set aside; the Assessing Officer may initiate fresh penalty proceedings after the High Court decides the admitted substantial question of law.

Ratio Decidendi: Where a substantial question of law raised in the assessee's quantum appeal has been admitted by the High Court and is pending, continuation or final adjudication of penalty proceedings under section 271AAC(1) r/w section 274 may be set aside as debatable pending the High Court's decision, permitting the assessing authority to reconsider initiation of penalty proceedings thereafter.

Issues: Whether the accused applicants were entitled to discharge under Section 227 of the Code of Criminal Procedure, 1973 in the absence of a subsisting predicate offence and identifiable proceeds of crime for the alleged offence of money laundering.

Analysis: The complaint under the Prevention of Money Laundering Act, 2002 was founded on the predicate offences arising from the two underlying criminal cases. The discharge orders in those predicate cases had held that the prosecution had not made out a prima facie case and, on that basis, no offence was found to have been committed. The Court treated those findings as meaning that no proceeds of crime had been generated from the scheduled offences. Relying on the statutory scheme of Sections 2(u), 3 and 4 of the Prevention of Money Laundering Act, 2002 and the principle that money-laundering is dependent on property derived or obtained as a result of criminal activity relating to a scheduled offence, the Court held that in the absence of subsisting predicate offences and proceeds of crime, the prosecution under the Act could not survive. The Court also noted that the attachment orders had been set aside and that the discharge orders in the predicate offences had attained finality.

Conclusion: The accused applicants were entitled to discharge and no charge could be framed against them for the alleged offence under the Prevention of Money Laundering Act, 2002.

Final Conclusion: The proceedings were terminated at the stage of charge, and all applicants stood discharged from the money-laundering case.

Ratio Decidendi: Money-laundering under the Prevention of Money Laundering Act, 2002 cannot be sustained unless there exists property constituting proceeds of crime derived or obtained from a subsisting scheduled offence; where the accused stand finally discharged in the predicate offence and no proceeds of crime survive, prosecution under the Act fails.

Outcome: Delay was condoned and the special leave petition was dismissed as covered by an earlier decision of the Court.

Issues: (i) Whether, for the purpose of valuation under Section 50C of the Income-tax Act, 1961, the multiplicative factor '1' (applicable to agricultural/residential land) should be applied to the subject Lal Dora property despite its actual commercial use as a godown.

Analysis: The Tribunal examined the revenue records and the identification of the subject property as agricultural/residential (Lal Dora) in state records and the agreement to sell. The Tribunal noted that the building's commercial use as a godown was not recognized by revenue authorities by way of reclassification, levy of penalty, or any alteration in official revenue records. The Tribunal applied the principle that circle rate multiplicative factors for stamp duty are to be determined by the character of the property as shown in revenue records maintained by competent authorities, and that mere unauthorised or factual commercial use does not amount to deemed conversion for valuation purposes unless recognized by revenue authorities.

Conclusion: The multiplicative factor '1' is to be applied for valuation under Section 50C; the application of multiplicative factor '3' by the Assessing Officer is invalid. This conclusion is in favour of the Assessee.

Ratio Decidendi: For stamp-duty valuation under Section 50C, the multiplicative factor applicable to circle rates is determined by the property's classification in official revenue records; unrecognised or unauthorised change in use does not alter that classification for valuation purposes.

Issues: Whether the final assessment orders passed under section 144C(13) read with section 153 of the Income-tax Act, 1961 are barred by limitation; specifically, whether the time limits prescribed under section 153 apply to proceedings under section 144C(13).

Analysis: The Tribunal examined the competing positions, including the Madras High Court decision in Roca Bathroom Products (P.) Ltd., and the pendency of related matters before the Supreme Court. Having considered the statutory scheme of section 144C and section 153 and the timeline for DRP and Assessing Officer action, the Tribunal compared the statutory due dates with the actual dates of passing final orders for the six assessment years. The dates were not disputed by the Revenue and the Tribunal found that in each assessment year the final assessment order was passed after the limitation period as computed with reference to section 153. The Tribunal therefore applied the principle that the provisions of sections 144C and 153 are mutually inclusive for computing the limitation in such remand/DRP cases and that where the final order is beyond the outer time-limit under section 153, the order is time-barred.

Conclusion: The final assessment orders for the six assessment years are time-barred and are quashed; the appeals are allowed in favour of the assessee.

Ratio Decidendi: Where assessment proceedings involve section 144C remand/DRP processes, the limitation for passing the final assessment order must be computed with reference to section 153 of the Income-tax Act, 1961; if the final order is passed beyond that outer time limit, it is barred by limitation.

Issues: Whether the final assessment orders passed under section 144C(13) read with section 153 of the Income-tax Act, 1961 are barred by limitation.

Analysis: Relevant legal framework comprises the timelines prescribed under section 144C (including draft order, DRP directions and finalisation) and the outer limitation periods in section 153 (including provisos and extended periods). The decision in Roca Bathroom Products P. Ltd. (Madras High Court) treated the DRP proceedings as part of assessment proceedings and held that the outer time limits under section 153 apply to finalisation after remand; that approach was followed by the Tribunal. The assessee supplied uncontested date charts showing draft assessment dates, DRP direction dates and the due dates for final assessment under section 144C(13) r.w.s. 153. The final assessment orders were passed after the applicable due dates. Competing contentions that section 144C is a complete code with its own self-contained timelines and that the non-obstante clause excludes section 153 were considered and distinguished on statutory construction, practical consequences and on authority supporting application of section 153 timelines to post-draft proceedings.

Conclusion: The final assessment orders passed beyond the period of limitation under section 144C(13) read with section 153 are without jurisdiction and are quashed; decision is in favour of the assessee.

Issues: Whether the claim of long term capital loss of Rs. 183,00,38,564/- on sale of shares is allowable where the assessee furnished valuation report and documentary evidence before the first appellate authority and the Assessing Officer in remand reports did not present an independent valuation or concrete contrary material to rebut the assessee's valuation.

Analysis: The issue centres on sufficiency and veracity of evidence substantiating LTCL on sale of shares to an unrelated foreign purchaser. The factual matrix shows sale to an unrelated Singapore entity and production before the appellate forum of documentary evidence including demat statements, agreements and an independent valuation report (dated 22.02.2021). The first appellate authority forwarded these materials to the A.O. for remand verification and multiple remand reports and opportunities were exchanged. The A.O.'s initial objections related to non-submission of certain documents and funding being routed through related entities; however, the assessee demonstrated that earlier name changes and provided demat/purchase records before the appellate authority. In the second remand report the A.O. did not identify any specific deficiency in the independent valuer's determination of value nor did the department produce its own valuation or evidence quantifying market value on the date of sale. Rule 11UA (NAV considerations) and procedural notice under Section 250 were part of the appellate record; the assessee's chart showed sale prices were not below NAV and the department failed to controvert the valuation with affirmative proof. Where the transaction is between unrelated parties and the assessee produces an independent valuation and corroborative documents, the onus rests on the revenue to rebut with concrete contrary material; a mere assertion or failure to produce an alternative valuation is inadequate to summarily reject the assessee's claim.

Conclusion: The claim of long term capital loss of Rs. 183,00,38,564/- is allowable; the Revenue's grounds are dismissed and the first appellate authority's decision upholding the LTCL is affirmed in favour of the assessee.

Final Conclusion: The appellate tribunal affirms the appellate authority's allowance of the LTCL, holding that in absence of independent contrary evidence from the revenue the valuation and documentary evidence produced by the assessee suffice to establish the genuineness and quantum of the loss.

Ratio Decidendi: Where an assessee produces an independent valuation and supporting documentary evidence for share sale to an unrelated party, and the revenue fails to produce a contrary valuation or concrete rebuttal during remand/appellate proceedings, the assessing officer cannot summarily reject the assessee's valuation and disallow the long term capital loss.

Issues: (i) whether certain companies were correctly selected or excluded as comparables for transfer pricing benchmarking, including the use of segmental data; (ii) whether the assessee was entitled to risk adjustment and working capital adjustment; (iii) whether bank charges and provision for doubtful debts were to be treated as operating expenses while computing margins of comparables; and (iv) whether the Revenue's Rule 27 application based on an adjustment not arising from the assessment order was maintainable.

Issue (i): whether certain companies were correctly selected or excluded as comparables for transfer pricing benchmarking, including the use of segmental data.

Analysis: The comparability exercise turned on functional similarity and the availability of reliable segmental information. One comparable was remanded for reconsideration after examining its segmental data. Another was directed to be examined on the basis of its ARMS segment. A third comparable was directed to be rejected following the earlier year's view. The newly challenged comparable was sent back for examination of its full business profile and the additional material produced.

Conclusion: The issue was partly decided in favour of the assessee, with some comparables remanded for fresh examination and one comparable rejected.

Issue (ii): whether the assessee was entitled to risk adjustment and working capital adjustment.

Analysis: The adjustment question was governed by the comparable risk profile and the directions already issued in the assessee's earlier years. Risk adjustment was not finally quantified and was therefore sent back for fresh determination after the assessee demonstrates the risk assumed and the differences in risk borne by comparables. Working capital adjustment was to be granted in accordance with the DRP's directions and methodology.

Conclusion: Risk adjustment was remanded for reconsideration, while working capital adjustment was directed to be allowed.

Issue (iii): whether bank charges and provision for doubtful debts were to be treated as operating expenses while computing margins of comparables.

Analysis: The operating margin computation required expenses closely linked to business operations to be treated as operating in nature. Bank charges and provision for doubtful debts were held to have a direct nexus with operations, and the margin computation was required to reflect that treatment.

Conclusion: The issue was decided in favour of the assessee and remanded for recomputation by treating those items as operating expenses.

Issue (iv): whether the Revenue's Rule 27 application based on an adjustment not arising from the assessment order was maintainable.

Analysis: The application sought to support an enhancement that did not emanate from the assessment order, and therefore lacked a proper foundation in the impugned order under appeal.

Conclusion: The Rule 27 application was dismissed.

Final Conclusion: The transfer pricing disputes were not finally determined on several comparability and adjustment questions, with partial relief granted to the assessee and consequential remands for fresh examination, while the Revenue's separate application failed.

Ratio Decidendi: Comparable selection in transfer pricing must rest on functional similarity and reliable segmental data, and adjustments such as risk and working capital must be determined in accordance with the comparable profile and the directions already applicable to the assessee's case.

Issues: (i) Whether the final assessment orders passed under section 144C(13) read with section 153 of the Income-tax Act, 1961, for AYs 2009-10 to 2012-13, which were issued beyond the applicable period of limitation, are without jurisdiction and liable to be quashed.

Analysis: The dispute concerns the temporal interplay between section 144C (the DRP framework with in-built timelines) and section 153 (general outer time-limits for completion of assessment). The Tribunal examined the legislative scheme of section 144C, the presence of non-obstante language, and the timelines prescribed for draft order, filing of objections, DRP directions and finalisation of assessment. The Tribunal considered binding and persuasive authorities addressing whether the outer time limits under section 153 apply to proceedings remanded involving DRP, including the Madras High Court decision in Roca Bathroom Products P. Ltd., and contrasted those with the Revenue's submissions that section 144C is a self-contained code whose timelines operate independently. The Tribunal evaluated undisputed date charts for AYs 2009-10 to 2012-13 showing due dates computed with reference to section 144C(13) read with section 153 and the actual dates on which final orders were passed, and applied the legal conclusion that proceedings remanded and processed via DRP remain subject to the outer limitation under section 153 and to the statutory timelines embedded in section 144C.

Conclusion: The final assessment orders for AYs 2009-10 to 2012-13, having been passed beyond the period of limitation determined with reference to section 144C(13) read with section 153, are without jurisdiction and are quashed; accordingly the appeals are allowed in favour of the assessee.

Ratio Decidendi: Where assessment proceedings involve remand to the DRP under section 144C, the period of limitation for passing the final assessment order must be determined with reference to section 144C read with section 153; final orders passed beyond the applicable limitation are without jurisdiction and liable to be quashed.

Issues: Whether the reassessment notice issued under Section 148 for AY 2014-15 is invalid for want of prior approval from the specified authority under Section 151 when more than three years have elapsed from the end of the relevant assessment year.

Analysis: Section 151 prescribes the specified authority whose prior sanction is a precondition for issuance of a notice under Section 148; the new regime (effective 1 April 2021) requires a higher level of authority where more than three years have elapsed. The statutory scheme links the time elapsed with the level of authority competent to grant sanction and makes grant of sanction a jurisdictional precondition to assume jurisdiction under Section 148. Non-compliance with the mandatory procedure under Section 151 vitiates the reassessment proceedings. The proviso in the legislative scheme and the temporal adjustments under TOLA operate to determine whether extended time for sanction applies, but do not substitute for the requirement that the sanction must be granted by the authority specified for the relevant elapsed period. Factual material on record shows the sanction was not accorded by the authority specified under Section 151(ii) for notices issued after three years.

Conclusion: The notice under Section 148 is invalid for want of prior approval by the specified authority under Section 151(ii); the reassessment and related proceedings are quashed. The appeal is allowed in favour of the assessee.

Issues: Whether crude palm oil consignments declared as "edible grade" are entitled to benefit under Notification No.21/2002-Cus. (Sl. No.30(II)(A)) where laboratory test reports show acid value greater than 10, given that the notification specifies "acid value of 4 or more" without an upper limit.

Analysis: Notification No.21/2002 as amended (Sl. No.30(II)(A)) grants exemption to crude palm oil of edible grade described as having an acid value of "4 or more" and specified carotenoid range; the text of the notification contains no express upper limit on acid value. Conflicting laboratory reports were placed before the authorities; some reports recorded acid values above 10 while others recorded lower values. The authorities also permitted reprocessing of the imported goods and clearance after Port Health Officer (PHO) certification. Relevant precedents interpreting the notification (including High Court and Supreme Court decisions) confirm that where the exemption notification unambiguously specifies "4 or more" an upper limit cannot be read into the notification, and that such exemptions must be given effect unless the notification itself is ambiguous. The Revenue's reliance on external standards or circulars imposing a maximum acid value does not alter the clear wording of the exemption entry in the notification.

Conclusion: The benefit of Notification No.21/2002-Cus. is available to the consignments declared as crude palm oil (edible grade) despite laboratory reports showing acid value above 10; the impugned orders denying the exemption are set aside and the appeals are allowed (in favour of the assessee).