Issues: (i) Whether the imported goods were classifiable as relays under CTI 8536 49 00 or as feeder management intelligent electronic devices under CTI 8536 90 90; (ii) whether the goods, other than MICOM relays, were eligible for exemption for relays of contact rating upto 7 amperes under Notification No. 12/2012 dated 17.03.2012; (iii) whether penalties under sections 112, 114A and 114AA of the Customs Act, 1962 were sustainable.

Issue (i): Whether the imported goods were classifiable as relays under CTI 8536 49 00 or as feeder management intelligent electronic devices under CTI 8536 90 90.

Analysis: The relevant classification turned on the true character of the goods and their principal function. The goods were shown by the technical literature and market description to be relays used for control, protection and supervision of electrical systems, while the additional digital or monitoring features were only ancillary. Under Note 3 to Section XVI of the Customs Tariff Act, 1975, a composite machine is classified by the component performing the principal function. The residual entry could not be applied merely because the goods had advanced features.

Conclusion: The goods were classifiable as relays under CTI 8536 49 00, not under CTI 8536 90 90, in favour of the assessee.

Issue (ii): Whether the goods, other than MICOM relays, were eligible for exemption for relays of contact rating upto 7 amperes under Notification No. 12/2012 dated 17.03.2012.

Analysis: The record showed that the three contested products other than MICOM had contact ratings of 5 amperes, and no contrary evidence was produced by the department. Since the exemption covered relays of contact rating upto 7 amperes, those products satisfied the notification condition. MICOM relays stood on a different footing because their contact rating exceeded 7 amperes.

Conclusion: The three non-MICOM products were entitled to exemption, while MICOM relays were not, in favour of the assessee in part.

Issue (iii): Whether penalties under sections 112, 114A and 114AA of the Customs Act, 1962 were sustainable.

Analysis: Once the three non-MICOM products were held to be correctly classified and exempt, the differential duty and consequential penalty foundation to that extent disappeared. As to MICOM, the duty and interest had been paid before issuance of the show cause notice, and the basis for alleging wilful misuse of false particulars was not sustainable on the facts found. The individual penalties also failed because the premise that all the goods had contact ratings above 7 amperes was incorrect.

Conclusion: The penalties under sections 112, 114A and 114AA were set aside, in favour of the assessee and the individual appellants.

Final Conclusion: The classification was accepted in favour of the appellants, the exemption was allowed for the non-MICOM relays, the differential duty demand for those goods and the related penalties were set aside, and the appeals were allowed to the indicated extent.

Ratio Decidendi: Where imported goods perform the essential function of relays, ancillary technological features do not displace classification under the specific relay entry, and exemption conditions are to be tested on the actual contact rating of the goods proved on record.

Issues: Whether the appellant was entitled to bail in the pending money-laundering proceedings.

Analysis: The appellant faced prosecution under the Prevention of Money Laundering Act, 2002. The Court noted that co-accused had already been granted bail by the High Court or by the Court itself. The Court also took into account the appellant's age and the fact that he had remained in custody for more than two years. In view of these factors, the Court found it appropriate to extend the benefit of bail.

Conclusion: Bail was granted and the impugned order was set aside.

Issues: Whether electricity charges recovered from occupants and amounts collected towards transformer installation were liable to service tax under the category of Management, Maintenance or Repair Service.

Analysis: The supply of electricity to tenants was treated as a sale of goods, since electricity is goods and the charges were separately billed on actual consumption. Once the transaction was in the nature of sale of goods, the amounts realised for electricity could not be brought within the taxable value of a service. The same principle applied to the transformer installation charges, as the appellant recovered less than the actual cost and acted only as a conduit for recovering expenses connected with supply of electricity. In view of the nature of the transaction, no service tax could be sustained on either component, and the penalty followed the same fate.

Conclusion: The demand of service tax on electricity charges and transformer installation charges was unsustainable and was set aside. The appellant was held not liable to service tax under Management, Maintenance or Repair Service, and no penalty survived.

Issues: (i) Whether service of the statutory notice under the Negotiable Instruments Act was duly proved. (ii) Whether the cheques were issued in discharge of a legally enforceable debt or liability and the statutory presumption stood rebutted.

Issue (i): Whether service of the statutory notice under the Negotiable Instruments Act was duly proved.

Analysis: The notice was returned with an endorsement of absence. The evidence accepted by the Court showed that the drawer was away for about fifteen days and the endorsement did not establish deliberate avoidance of service. In the absence of further steps to secure service, the Court accepted the finding that due service was not established beyond doubt.

Conclusion: Service of the statutory notice was not proved against the respondent.

Issue (ii): Whether the cheques were issued in discharge of a legally enforceable debt or liability and the statutory presumption stood rebutted.

Analysis: Under Section 138 and the presumptions under Sections 118 and 139, the holder must establish the foundational facts, after which the drawer may rebut the presumption on a preponderance of probabilities. The Court found that the complainant failed to prove the alleged loan with specificity, there was no supporting agreement, the evidence did not satisfactorily show payment of the alleged loan amount, and the surrounding circumstances supported the defence version that the cheques were linked to business dealings rather than an enforceable debt. On that basis, the presumption was treated as rebutted.

Conclusion: The cheques were not proved to have been issued in discharge of a legally enforceable debt or liability, and the presumption stood rebutted.

Final Conclusion: The appeal failed and the acquittal was left undisturbed because the essential ingredients of the offence under Section 138 were not established.

Ratio Decidendi: For an offence under Section 138 of the Negotiable Instruments Act, the complainant must prove that the cheque was issued towards a legally enforceable debt or liability and the accused may rebut the statutory presumption by showing a probable defence on the preponderance of probabilities.

Issues: Whether the petitioner, whose GST registration was cancelled for non-filing of returns, was entitled to restoration of registration after filing the pending returns and paying the tax dues.

Analysis: The cancellation of registration was founded on non-filing of returns under the GST law. The governing procedural framework permits issuance of a show-cause notice and, where the person furnishes all pending returns and makes full payment of tax dues along with applicable interest and late fee, the proper officer may drop the proceedings and pass the prescribed order. The petitioner had already filed the returns and deposited the requisite dues, and the Court followed the approach taken in similar matters to grant a restoration route by directing the petitioner to move the competent authority for consideration in accordance with law.

Conclusion: The petitioner was held entitled to seek restoration of GST registration, and the competent authority was directed to verify the application and restore the registration in accordance with law.

Ratio Decidendi: Where GST registration is cancelled for non-filing of returns, but the registered person subsequently furnishes the pending returns and pays the tax dues with applicable interest and late fee, the competent authority may consider restoration of registration in accordance with the statutory procedure.

Issues: Whether the detained consignment of perishable goods was liable to be released in favour of the petitioner on compliance with the amount payable under section 129(1)(a) of the applicable goods and services tax law.

Analysis: The goods were stated to be perishable in nature. The revenue did not place any concrete or unimpeachable material to show that the petitioner was not the owner of the consignment, and the impugned demand order did not record such a basis. In these circumstances, and in view of the statutory scheme governing detention and release of goods in transit, release could be directed upon compliance with the amount payable under section 129(1)(a).

Conclusion: The detained consignment was directed to be released in favour of the petitioner on compliance with section 129(1)(a) of the applicable goods and services tax law.

Ratio Decidendi: Where detained goods are perishable and the authority has not established a prima facie basis to dispute the consignor's ownership, the goods may be released on compliance with the statutory amount payable for detention.

Issues: Whether advances received from customers/flat purchasers in the ordinary course of the assessee's real estate business could be treated as unexplained cash credit under section 68 of the Income-tax Act, 1961.

Analysis: The assessee was engaged in real estate development and followed the project completion method consistently. The record showed that customer advances were received in the ordinary course of business, adjusted against sales in the same or subsequent years, and the corresponding sales were offered to tax. The revenue had also accepted the same accounting pattern in earlier years. In such circumstances, the advances could not be characterised as unexplained liabilities or cash credits. Sustaining the addition would also amount to taxing the same receipts twice. The addition was further untenable because the sales reflected in the books were accepted while the linked advances were selectively brought to tax without rejecting the books as a whole.

Conclusion: The addition under section 68 was not sustainable and had to be deleted; the issue was decided in favour of the assessee.

Final Conclusion: The appellate order was set aside and the assessment addition on account of customer advances was deleted, resulting in relief to the assessee.

Ratio Decidendi: Trade advances received in the ordinary course of a real estate business and regularly adjusted against sales under a consistently accepted project completion method cannot be taxed as unexplained cash credits under section 68 absent a valid basis for disturbing the settled accounting treatment.

Issues: (i) whether the arm's length guarantee commission for the corporate guarantee jointly extended to the foreign associated enterprise was correctly restricted to 0.25% in the assessee's hands; (ii) whether proportionate interest on borrowings could be disallowed in relation to loans advanced to AAIPL and SCA LLP.

Issue (i): whether the arm's length guarantee commission for the corporate guarantee jointly extended to the foreign associated enterprise was correctly restricted to 0.25% in the assessee's hands.

Analysis: The guarantee was extended jointly by the assessee and its subsidiary, and the transfer pricing rate determined by the TPO at 0.5% was treated by the appellate authority as requiring equal sharing between both guarantors. The Tribunal accepted that the risk arising from the guarantee was borne jointly and that half of the arm's length commission was attributable to the assessee.

Conclusion: The restriction of the guarantee commission to 0.25% in the assessee's hands was upheld.

Issue (ii): whether proportionate interest on borrowings could be disallowed in relation to loans advanced to AAIPL and SCA LLP.

Analysis: The loans were found to have been advanced in the course of the assessee's real estate business and for commercial reasons, including project requirements, financial stress in the group entities, litigation, delays, and the need to protect the business interest of the assessee. Applying the settled principle that interest on borrowed capital is allowable where the borrowing is for business purposes and commercial expediency is shown, the Tribunal held that the absence of interest income from the advances did not justify disallowance under the Act.

Conclusion: The deletion of the proportionate interest disallowance relating to AAIPL and SCA LLP was upheld.

Final Conclusion: The Revenue's challenge failed on both the transfer pricing issue and the interest disallowance issue, and the relief granted to the assessee by the appellate authority was sustained in full.

Ratio Decidendi: Where an advance or guarantee is shown to be made in the course of business and in commercial expediency, interest or guarantee commission consequences must be tested on that footing, and the Revenue cannot substitute its view for that of a prudent businessman absent material to the contrary.

Issues: Whether the Principal Commissioner was justified in revising the reassessment order under section 263 by treating the jewellery purchase expenditure as a taxable perquisite in the assessee's hands under section 17(2).

Analysis: The jewellery bills were found during search from the assessee's premises, but the expenditure was found to have been incurred by the company out of unaccounted cash generated through bogus billing. The record did not establish any employer-employee relationship between the assessee and the company, which was necessary for bringing the amount within the scope of perquisite taxation under section 17(2). On these facts, the reassessment order could not be characterised as erroneous and prejudicial to the interests of the Revenue merely because the Principal Commissioner viewed a different tax treatment as possible.

Conclusion: The revision under section 263 was not warranted and the addition under section 17(2) in the assessee's hands was unjustified.

Issues: Whether depreciation under section 32(1)(ii) of the Income-tax Act, 1961 was allowable on non-compete fees capitalised as an intangible asset.

Analysis: The assessee had capitalised non-compete fees under business purchase agreements and had been claiming depreciation on the written down value in earlier years. The issue had already been decided in the assessee's favour in its own case for earlier assessment years, and the same reasoning was followed for the years in appeal. In this factual setting, the claim for depreciation on non-compete fees was found to be allowable under section 32(1)(ii).

Conclusion: Depreciation on non-compete fees was allowed in favour of the assessee.

Ratio Decidendi: Non-compete fee capitalised as an intangible asset is eligible for depreciation under section 32(1)(ii) of the Income-tax Act, 1961 when the claim is supported by the established treatment of the asset and prior favourable adjudication on the same issue.

Issues: (i) Whether reassessment under sections 147/148 of the Income-tax Act, 1961 was without jurisdiction because the matter ought to have been proceeded with under section 153C of the Income-tax Act, 1961 on the basis of material found in the search of a third party; (ii) Whether the reassessment was invalid because it was founded only on borrowed satisfaction from the investigation material without independent inquiry.

Issue (i): Whether reassessment under sections 147/148 of the Income-tax Act, 1961 was without jurisdiction because the matter ought to have been proceeded with under section 153C of the Income-tax Act, 1961 on the basis of material found in the search of a third party.

Analysis: The reassessment was founded exclusively on material seized in the search of another person. The special mechanism under section 153C applies where material belonging to or pertaining to a person other than the searched person is found in search proceedings, and that mechanism overrides the general reassessment route. In the absence of any independent post-search material and in the absence of the required satisfaction note from the searched person's Assessing Officer, the general reassessment provisions could not be used to bypass section 153C.

Conclusion: The reassessment under sections 147/148 was without jurisdiction and was rightly quashed in favour of the assessee.

Issue (ii): Whether the reassessment was invalid because it was founded only on borrowed satisfaction from the investigation material without independent inquiry.

Analysis: The challenge on borrowed satisfaction was considered on the footing that the Assessing Officer had acted on information from the investigation wing and the insight portal. The record, however, showed that the statutory procedure under the reassessment regime had been followed and the issue had been separately examined in earlier proceedings. Since the reassessment itself was already held to be jurisdictionally defective on the section 153C ground, this challenge did not alter the result of the appeals.

Conclusion: This ground was decided against the assessee, but it did not affect the ultimate quashing of the reassessment orders.

Final Conclusion: The core jurisdictional defect lay in the use of sections 147/148 instead of the special search-related mechanism under section 153C, and that defect vitiated the reassessment orders for both years.

Ratio Decidendi: Where reassessment is triggered solely by search material relating to a third person, the Assessing Officer cannot invoke sections 147/148 in bypass of section 153C unless the statutory satisfaction requirement is first met and some independent post-search material exists.

Issues: Whether the customs authority should be directed to consider the petitioner's application for release of the seized consignment under Section 110A of the Customs Act, 1962 after completion of the pending certification proceeding before the jurisdictional Magistrate.

Analysis: The consignment had been seized under Section 110 of the Customs Act, 1962 and a certification proceeding under sub-section (1B) of that provision was stated to be pending before the jurisdictional Magistrate. The petitioner's application for release under Section 110A was also pending. In that situation, the Court directed the Magistrate to conclude the certification proceeding within a fixed time and directed the customs authority to consider the release application thereafter by passing a reasoned order in accordance with law.

Conclusion: The petitioner was not granted immediate final relief on merits, but the customs authority was required to decide the release application after the Magistrate's conclusion, with liberty reserved to challenge any adverse order before the appropriate forum.

Issues: Whether appeals filed in the name of the corporate debtor after commencement of CIRP could be permitted to be amended by substituting the suspended director as appellant after expiry of the limitation period, and whether such appeals were maintainable.

Analysis: The Tribunal applied the principle that once CIRP has commenced, an appeal filed in the name of the corporate debtor is not maintainable if the filing is beyond the prescribed period under Section 61(2) of the Insolvency and Bankruptcy Code, 2016. It held that such an appeal is not a merely defective proceeding capable of later correction by amendment, but an incompetent appeal. The Tribunal also held that the law declared by the Supreme Court on this issue is binding under Article 141 of the Constitution of India, and that earlier orders permitting amendments in other matters could not prevail over that binding declaration.

Conclusion: The amendment applications were rightly rejected, and the appeals were not maintainable as they were filed by the corporate debtor after commencement of CIRP and beyond limitation.

Issues: (i) Whether the appellant was entitled to claim tax exemption after disposal of MA No. 442/2011 on 16.08.2011; (ii) whether the sanctioned scheme SS-08 was deemed to have been consented to by the State of Orissa under Section 19(2) of the Sick Industrial Companies (Special Provisions) Act, 1985; (iii) whether the appellant made out a case before the NCLT for a direction granting exemption from payment of Entry Tax till 2014 under the sanctioned scheme.

Issue (i): Whether the appellant was entitled to claim tax exemption after disposal of MA No. 442/2011 on 16.08.2011

Analysis: The relief sought in MA No. 442/2011 included a direction to the State for implementation of the unimplemented provisions of the sanctioned scheme, but the BIFR only discharged the company from the purview of SICA and did not grant the requested enforcement relief. The order of 16.08.2011 was not challenged within limitation and therefore attained finality. The sanctioned scheme was also time-bound and ran only up to 2014.

Conclusion: The appellant was not entitled to claim tax exemption after disposal of MA No. 442/2011 on 16.08.2011.

Issue (ii): Whether the sanctioned scheme SS-08 was deemed to have been consented to by the State of Orissa under Section 19(2) of the Sick Industrial Companies (Special Provisions) Act, 1985

Analysis: Deemed consent under Section 19(2) applies where no consent is communicated within the prescribed time. Here, the State's representative appeared before the BIFR during the objections hearing and expressly stated that the Government had no policy to grant relief to sick companies. That statement was treated as a clear denial of consent. The cited precedents on deemed consent were held distinguishable on their facts.

Conclusion: The sanctioned scheme SS-08 was not deemed to have been consented to by the State of Orissa under Section 19(2) of the Sick Industrial Companies (Special Provisions) Act, 1985.

Issue (iii): Whether the appellant made out a case before the NCLT for a direction granting exemption from payment of Entry Tax till 2014 under the sanctioned scheme

Analysis: Since the State had not consented to the relevant relief in the scheme, the Entry Tax exemption clause was not enforceable against it. The earlier High Court order merely required the NCLT to decide the pending application according to law and did not decide the merits. The subsequent notification of 24.05.2017 did not revive a time-barred or otherwise unavailable claim, and the application was held to be unsustainable.

Conclusion: The appellant did not make out a case before the NCLT for a direction granting exemption from payment of Entry Tax till 2014 under the sanctioned scheme.

Final Conclusion: The sanctioned scheme could not be enforced against the State for the claimed Entry Tax relief, the challenged order was upheld, and the appeal failed.

Ratio Decidendi: Deemed consent under Section 19(2) arises only where no response is communicated within the prescribed period; an express communication of non-consent prevents the scheme from becoming binding on the State for the disputed relief.

Issues: Whether the petitioners were entitled to regular bail in the tax prosecution and whether continued custody was warranted in the facts of the case.

Analysis: The petition concerned alleged offences under the Central Excise Act, the Finance Act and the Central Goods and Services Tax Act arising from the company's alleged failure to discharge tax liability. The petitioners had already remained in custody for substantial periods in the predicate and connected proceedings, part payment had been made towards the liability, and the Court found that no useful purpose would be served by further incarceration. The Court also recorded that the pending attachment of movable and immovable assets would continue to secure the claims of investors and customers.

Conclusion: The petitioners were granted regular bail subject to furnishing bail bonds to the satisfaction of the Chief Judicial Magistrate, Hisar.

Issues: (i) Whether the service tax demand on transportation charges was sustainable where the Revenue's computation was challenged as erroneous and the assessee had already discharged tax on part of the amounts or obtained exemption in respect of export-related transportation; (ii) Whether exemption under the relevant service tax notifications could be denied merely because Forms EXP-1 and EXP-2 were filed belatedly or other procedural requirements were not met; (iii) Whether penalty under Section 78 and penalty under Section 77(2) of the Finance Act, 1994 were leviable.

Issue (i): Whether the service tax demand on transportation charges was sustainable where the Revenue's computation was challenged as erroneous and the assessee had already discharged tax on part of the amounts or obtained exemption in respect of export-related transportation?

Analysis: The transportation figures adopted by the Revenue were found to be unsupported in several periods, while the assessee's audited balance sheets and chartered accountant's certificate showed lower actual transportation expenditure. The record also showed that, for certain components, service tax had already been paid by the service provider or had been discharged by the assessee under VCES, and those amounts could not be demanded again. For export-linked transportation, the assessee established eligibility to exemption and the demand was not sustainable to the extent the underlying factual basis for taxation failed.

Conclusion: The demand was set aside to the extent the Revenue had wrongly computed the taxable value or demanded tax again on amounts already discharged or exempt.

Issue (ii): Whether exemption under the relevant service tax notifications could be denied merely because Forms EXP-1 and EXP-2 were filed belatedly or other procedural requirements were not met?

Analysis: The exemption notifications governing transport of goods by road for export were treated as conferring a substantive benefit once the export condition and other material requirements were satisfied. The delay in filing the prescribed forms was held to be only a procedural lapse. The decision applied the settled principle that procedural conditions are directory where their breach does not defeat the substantive entitlement and where no dispute existed about the export nexus of the services.

Conclusion: Exemption could not be denied merely for procedural delay, and the assessee was held entitled to the benefit of the export notifications for the eligible transportation charges.

Issue (iii): Whether penalty under Section 78 and penalty under Section 77(2) of the Finance Act, 1994 were leviable?

Analysis: The demand arose from the assessee's own records and documents, and no material was brought to establish suppression, wilful misstatement, or mala fide intent to evade tax. In the absence of such mens rea, the ingredients for penalty under Section 78 were not made out. The smaller penalty under Section 77(2) was also waived considering the overall facts and bona fides.

Conclusion: Penalty under Section 78 was set aside in toto, and penalty under Section 77(2) was waived.

Final Conclusion: The assessee succeeded on the principal tax demands and penalties, but the limited demand relating to late payment of service tax that was not contested was left undisturbed.

Ratio Decidendi: A substantive exemption cannot be denied for mere procedural non-compliance where the export nexus and other material conditions are satisfied, and penalty is not sustainable in the absence of evidence of suppression or wilful misstatement.

Issues: Whether rule 2(a) of the General Rules for the Interpretation of the Customs Tariff Act, 1975 applied so as to treat the imported parts as complete mobile phones and classify them under CTI 8517 14 00/8517 12 19 instead of as mobile phone parts.

Analysis: The imported goods were examined along with the Chartered Engineer's reports, which stated that the consignments were received in disassembled or unassembled condition and formed incomplete mobile phones. The reports also indicated that battery, camera, software, testing, and other processes were still required, and they did not conclusively establish that the goods, as imported, possessed the essential character of complete mobile phones. In a classification dispute, the burden lay on the department to prove the proposed reclassification, and the impugned order incorrectly shifted that burden onto the importer. The material on record was insufficient to show that the goods were complete mobile sets falling within rule 2(a).

Conclusion: Rule 2(a) did not justify reclassification of the imported goods as complete mobile phones, and the appellant succeeded on the classification issue.

Issues: (i) Whether the extended period of limitation could be invoked on the allegation of wilful misstatement or suppression of facts in a customs classification dispute; (ii) whether the duty demand, penalty under section 114A, and confiscation under section 111(m) of the Customs Act, 1962 could be sustained.

Issue (i): Whether the extended period of limitation could be invoked on the allegation of wilful misstatement or suppression of facts in a customs classification dispute.

Analysis: The dispute arose from a difference in classification of the imported goods. The importer had declared a tariff item in the Bills of Entry, while the department took a different view on classification. A mere difference of opinion on classification, by itself, does not establish suppression of facts or wilful misstatement. The goods had been physically examined and all relevant information had been furnished. The further findings about changing classification to obtain lower duty were not part of the show cause notice and could not be relied upon to sustain invocation of the extended period. The statements recorded under section 108 were also not relied upon in accordance with section 138B.

Conclusion: The extended period of limitation was not invokable.

Issue (ii): Whether the duty demand, penalty under section 114A, and confiscation under section 111(m) of the Customs Act, 1962 could be sustained.

Analysis: Penalty under section 114A depended on the same foundation as the extended period of limitation, and once that foundation failed, the penalty could not survive. Confiscation under section 111(m) requires misdeclaration of goods and is not attracted merely because the importer adopted a different classification in the Bill of Entry. Wrong classification or self-assessment error does not, by itself, render the goods liable to confiscation. Accordingly, the demand, penalty, and confiscation could not stand.

Conclusion: The duty demand, penalty, and confiscation were unsustainable and were set aside.

Final Conclusion: The order confirming the customs duty demand and consequential penalty and confiscation was set aside, and the appeal succeeded in full.

Ratio Decidendi: In a customs classification dispute, the extended period of limitation cannot be invoked unless suppression of facts or wilful misstatement with intent to evade duty is specifically established; a mere difference in classification or self-assessment error does not justify penalty or confiscation.

Issues: Whether sales-tax remission under the West Bengal Incentive Scheme, 1993 constituted a capital receipt or a revenue receipt.

Analysis: Under the purpose test, the character of a subsidy depends on its object rather than its mode of disbursement. The remission was designed to induce fresh fixed-capital investment, expansion and modernisation of industrial units in backward areas, and was not intended to assist the assessee's trading operations or profitability.

Conclusion: The sales-tax remission was a capital receipt and not a revenue receipt, in favour of the assessee.

Issues: Whether the sale consideration from the sale of shares could be treated as unexplained money on the allegation that the long-term capital gain transaction was a bogus penny-stock transaction.

Analysis: The assessee produced purchase and sale contract notes, bank records, broker ledgers, demat-account evidence and long-term capital-gain workings. The shares were acquired through a registered broker, held for more than twelve months, sold through a recognised stock exchange, and the sale was subject to securities transaction tax and other statutory charges. The Revenue relied solely on investigation information and did not establish any cash payment, unexplained deposit, connection with entry operators, or other material rebutting the documented transaction trail. Consistent coordinate-bench decisions concerning the same scrip supported acceptance of the documented transactions.

Conclusion: The share-sale transaction was genuine and the addition of the sale consideration as unexplained money under Section 69A of the Income-tax Act, 1961 was directed to be deleted in favour of the assessee.