Issues: Whether discretionary relief under Section 119(2)(b) of the Income Tax Act, 1961 could be refused where the assessee had offered and paid tax on the same interest income in two assessment years because of revision of Form 26AS by the deductor.

Analysis: Special circumstances for exercising discretion cannot be confined to a predetermined formula and must be assessed from the contextual facts. The same interest income was taxed in both assessment years after the deductor shifted its reporting through a revised Form 26AS. The assessee acted promptly by pursuing rectification and revision remedies from 2019; the eventual delay resulted substantially from the pending and rejected proceedings. Payment of tax twice on the same income constituted genuine hardship, and refusal of relief would result in unjust enrichment of the Revenue.

Conclusion: The rejection of condonation relief under Section 119(2)(b) was unsustainable; the assessee was entitled to submit a revised return for the relevant assessment year, subject to verification in accordance with law.

Issues: Whether reassessment could be initiated where the oil and gas exploration expenses and preliminary expenses had been examined during the original scrutiny assessment and accepted without additions.

Analysis: The reassessment reasons merely reflected a different view from that taken in the original scrutiny assessment. The assessee had replied to the relevant queries concerning all matters forming the basis of reassessment, and the Assessing Officer had accepted those replies without making additions. The absence of reproduction of the corresponding queries in the appellate order did not establish that the matters had not been examined. Reopening on the same material after such examination constituted a mere change of opinion.

Conclusion: The reassessment proceedings were invalid as being founded on a mere change of opinion, in favour of the assessee.

Issues: (i) Whether consideration received for assignment and surrender of rights, claims and entitlements connected with disputed partnership property and pending litigation was taxable as income from other sources; (ii) Whether expenditure claimed against interest income was allowable without evidence of its direct nexus with earning that income.

Issue (i): Whether consideration received for assignment and surrender of rights, claims and entitlements connected with disputed partnership property and pending litigation was taxable as income from other sources.

Analysis: The character of the receipt depended on the true nature of the right surrendered, rather than the description used in the deed. A proprietary or beneficial interest may constitute property notwithstanding that it is intangible. Conversely, where the right retained was only a right to pursue litigation or claim damages, it was a mere right to sue, which is not transferable under Section 6(e) of the Transfer of Property Act, 1882. On either characterisation, the one-time consideration for complete divestment of the underlying proprietary or litigative rights was capital in nature. Section 56 of the Income-tax Act, 1961 applies only to a receipt having the character of income and cannot convert an intrinsically capital receipt into taxable income merely because it is not charged under capital gains.

Conclusion: The consideration was a capital receipt and was not taxable as income from other sources; the addition was deleted in favour of the assessee.

Issue (ii): Whether expenditure claimed against interest income was allowable without evidence of its direct nexus with earning that income.

Analysis: Deduction under Section 57 of the Income-tax Act, 1961 requires proof that expenditure was laid out wholly and exclusively for making or earning income chargeable under the head income from other sources. The fact that the expenditure was lower than the interest income did not establish the requisite nexus, and no cogent supporting material was produced.

Conclusion: The expenditure claim was not allowable for want of evidence establishing its direct nexus with the interest income, against the assessee.

Final Conclusion: The gross consideration for surrender of the disputed rights could not be assessed under the residuary head as revenue income, while the unsupported expenditure claim against interest income remained disallowed.

Ratio Decidendi: A one-time receipt for complete surrender of proprietary rights or a mere litigative right is capital in character, and the residuary head cannot tax it unless it first constitutes income.

Issues: (i) Whether consideration for regional support services constituted royalty under Article 12(3)(a) of the India-Singapore Double Taxation Avoidance Agreement and Section 9(1)(vi) of the Income-tax Act, 1961; (ii) Whether such consideration constituted fees for technical services under Article 12(4)(b) of the India-Singapore Double Taxation Avoidance Agreement.

Issue (i): Whether consideration for regional support services constituted royalty under Article 12(3)(a) of the India-Singapore Double Taxation Avoidance Agreement and Section 9(1)(vi) of the Income-tax Act, 1961.

Analysis: The regional services comprised strategic, operational, sales, financial, legal, human-resources, marketing and communication support. Royalty requires consideration for the use or right to use specified intellectual property or information concerning industrial, commercial or scientific experience. The service arrangement did not transfer any proprietary information, or confer a right to use commercial, industrial or scientific experience. Application of the service provider's own knowledge and experience in rendering support is distinct from imparting or transferring that knowledge for independent use by the recipient. The confidentiality obligation further precluded commercial exploitation of exchanged information by the recipient.

Conclusion: The regional support-service consideration was not royalty, in favour of the assessee.

Issue (ii): Whether such consideration constituted fees for technical services under Article 12(4)(b) of the India-Singapore Double Taxation Avoidance Agreement.

Analysis: Even assuming that any service was managerial, technical or consultancy in nature, Article 12(4)(b) required that technical knowledge, experience, skill, know-how or process be made available so that the recipient could independently apply it. No material established such independent capability. Continued provision of the same services also showed that the recipient had not acquired the ability to apply any technical knowledge or know-how without assistance.

Conclusion: The regional support-service consideration was not fees for technical services, in favour of the assessee.

Final Conclusion: The receipts were business profits and, absent a permanent establishment in India, were not chargeable to tax in India.

Ratio Decidendi: Consideration for support services is neither royalty nor fees for technical services where the provider merely applies its own knowledge in performing the services without transferring a right to use information or making technical capability independently available to the recipient.

Issues: Whether excess stock found during survey, being stock of the assessee's regular trading business and explained as acquired from suppressed business profits, was assessable as unexplained investment under section 69B attracting section 115BBE, or as undisclosed business income under normal provisions.

Analysis: Section 115BBE applies consequentially only where income is validly chargeable under one of the specified deeming provisions, including section 69B. Excess stock of the same nature as regular business stock, found at regular business premises, and contemporaneously explained as having been acquired from undisclosed profits of that business, retains its business character unless material establishes an independent or extraneous source. The absence of purchase records established non-disclosure but did not, by itself, establish an unexplained source. The accounting entries introducing the stock into the books did not reduce the surrendered income: the purchase debit was reflected in closing stock, creditor entries were reversed, and the disclosed amount remained credited as taxable income. Consequently, no deduction, allowance, or set-off against deemed income arose.

Conclusion: The excess stock was undisclosed business income assessable at the normal rate and was not unexplained investment under section 69B; section 115BBE was inapplicable. This finding is in favour of the assessee.

Issues: Whether the long-term capital gain from sale of dematerialised equity shares was genuine and eligible for exemption, and whether additions for the sale proceeds and consequential commission expenditure were sustainable.

Analysis: The assessee furnished documentary material establishing the purchase, dematerialised holding and sale of shares. The transactions were routed through banking channels, and the supporting evidence was not disproved by any independent inquiry or material linking the assessee to alleged accommodation-entry providers. The adverse inference rested on general investigation material and the alleged status of another entity, without establishing that the assessee's specific transactions were bogus. Applying binding precedent and judicial consistency, the evidentiary onus stood discharged. The commission addition was consequential to the addition for the sale proceeds.

Conclusion: The long-term capital gain claim could not be denied, the addition under Section 68 was deleted, and the consequential addition under Section 69C was also deleted, in favour of the assessee.

Issues: Whether deduction under section 80IB could be denied where the audit report in Form No. 10CCB was timely prepared and uploaded as an attachment to the tax-audit report because separate electronic filing of that form was unavailable on the portal.

Analysis: The audit report was signed before the return-filing due date and its scanned copy was uploaded with Form No. 3CA-3CD on the date of filing the return. The Revenue did not disprove the absence of a separate electronic-filing facility or offline utility for Form No. 10CCB. The subsequent electronic filing after the facility became available confirmed compliance with the statutory requirement in substance. A technical deficiency not attributable to the assessee could not defeat the deduction.

Conclusion: The assessee substantially complied with the requirement of furnishing Form No. 10CCB; deduction under section 80IB must be allowed. The issue is decided in favour of the assessee.

Issues: Whether the penalty imposed on the customs broker for abetment of import undervaluation was sustainable in its quantum.

Analysis: The declared value of premium-brand engines was less than 10% of the redetermined value, supporting the finding that the goods had been knowingly undervalued. However, the customs broker had sought first-check examination before assessment, thereby bringing the consignment to the department's notice. The earlier licensing-regulation proceedings also recorded that the broker could not be held wholly responsible for the undervaluation, and a separate penalty had already been paid. In view of the broker's bona fide conduct and diligence, the penalty of Rs.15,00,000 was considered exorbitant relative to the established liability.

Conclusion: Penalty under Section 112(a) of the Customs Act, 1962 was sustained but reduced to Rs.1,00,000; the issue was decided partly in favour of the assessee.

Issues: (i) Whether the imported petroleum product declared as Naphtha under tariff item 27101229 could be reclassified as Natural Gasoline Liquid under tariff item 27101290; (ii) Whether WhatsApp chats and related digital material could support allegations of misdeclaration.

Issue (i): Whether the imported petroleum product declared as Naphtha under tariff item 27101229 could be reclassified as Natural Gasoline Liquid under tariff item 27101290.

Analysis: The classification framework placed the burden of proof on Revenue to displace the declared classification. Applying the Most Akin Test, the conflicting test reports did not establish that the product most closely resembled Natural Gasoline Liquid. The reports of specialised petroleum-testing agencies, based on substantially more detailed testing parameters and supplied samples, positively placed the product within the light Naphtha range, whereas the departmental reports were based on comparatively limited testing. The detailed specialised reports were preferred. The Benefit of Doubt arising from inconclusive or competing scientific material also operated against reclassification. The Common Parlance Test and the recognition of Natural Gasoline Liquid as a species within the broader genus of Naphtha further did not support disturbing the declared classification.

Conclusion: The declared classification as Naphtha under tariff item 27101229 could not be disturbed; the issue is decided in favour of the assessee.

Issue (ii): Whether WhatsApp chats and related digital material could support allegations of misdeclaration.

Analysis: Section 138C of the Customs Act, 1962 governed the Admissibility of Electronic Evidence. The statutory conditions for computer printouts, including the required certification or a legally admissible substitute, were not established. The digital material was also unsupported by admissible corroborative statements, with the required examination and cross-examination absent. No demonstrated commercial benefit from the alleged change of origin was established.

Conclusion: The WhatsApp chats and associated electronic material could not be relied upon to sustain allegations of misdeclaration; the issue is decided in favour of the assessee.

Final Conclusion: Revenue failed to displace the declared classification through reliable scientific evidence or legally admissible corroborative material, rendering the contrary adjudicatory findings unsustainable.

Ratio Decidendi: A declared classification cannot be displaced where Revenue fails to discharge its evidentiary burden through reliable testing applying the appropriate classification standard and relies on electronic material that does not satisfy statutory safeguards of admissibility.

Issues: Whether customs-duty appeal proceedings may continue after approval of the corporate debtor's resolution plan under the insolvency law.

Analysis: An approved resolution plan binds all creditors, including governmental authorities. Claims not forming part of the approved plan stand extinguished, and proceedings concerning such pre-approval statutory dues cannot be initiated or continued. The status of the disputed statutory dues under the approved plan was not disclosed; nevertheless, the binding effect of the plan or the extinguishment of excluded dues precluded continuation of the pending proceedings.

Conclusion: The appeal proceedings could not continue following approval of the resolution plan.

Issues: (i) Whether tax and recovery proceedings under the Maharashtra Value Added Tax Act could survive after approval of a clean-slate resolution plan settling government claims; (ii) Whether the statutory pre-deposit made for the tax appeal was refundable after extinguishment of the tax liability under the approved resolution plan.

Issue (i): Whether tax and recovery proceedings under the Maharashtra Value Added Tax Act could survive after approval of a clean-slate resolution plan settling government claims.

Analysis: Under Section 31 of the Insolvency and Bankruptcy Code, 2016, an approved resolution plan binds all stakeholders, including statutory authorities. A clean-slate resolution plan freezes claims included in it and extinguishes prior statutory dues not forming part of it, precluding initiation or continuation of proceedings for such dues. The tax department's claims for the relevant assessment years had been addressed under the approved plan.

Conclusion: The appellate order confirming the assessment and directing recovery was without jurisdiction and could not survive. This issue is decided in favour of the assessee.

Issue (ii): Whether the statutory pre-deposit made for the tax appeal was refundable after extinguishment of the tax liability under the approved resolution plan.

Analysis: The pre-deposit under Section 26(6A)(c) of the Maharashtra Value Added Tax Act, 2002 formed part of the disputed tax demand. As the approved resolution plan provided for full settlement of the department's dues, retaining the pre-deposit beyond the amount allocated under that plan would be impermissible.

Conclusion: The pre-deposit is refundable with applicable interest. This issue is decided in favour of the assessee.

Final Conclusion: Approval of the resolution plan extinguished the pre-resolution tax demand and required release of the related appellate pre-deposit.

Ratio Decidendi: An approved clean-slate resolution plan binds governmental authorities and extinguishes pre-approval statutory claims not preserved by the plan, preventing their enforcement and requiring refund of deposits retained solely against such claims.

Issues: Whether the power under Section 47-A of the Indian Stamp Act, 1899 can be invoked only upon material indicating wilful undervaluation with fraudulent intent to evade stamp duty; and whether the prior decisions imposing that requirement state the correct law.

Analysis: The competence of the statutory authority to issue a notice was distinguished from the alleged impropriety in setting its jurisdiction in motion. Section 47-A(1), on its plain terms, requires reason to believe that the market value or consideration has not been truly set forth, without expressly requiring proof of a culpable mindset. Importing fraudulent intention as an independent jurisdictional condition was considered inconsistent with literal construction of a taxing statute and capable of defeating a valuation-based enquiry. However, the contrary view had been expressed in binding three-Judge Bench decisions. Judicial discipline therefore required referral rather than departure from that precedent.

Outcome: The questions concerning the correctness of the precedent requiring wilful undervaluation and fraudulent intent were referred for consideration by a larger Bench; no final determination of stamp-duty liability or validity of the notice was made.

Issues: Whether the statutory presumption of a legally enforceable debt arising from an admitted cheque signature stood rebutted, rendering the concurrent conviction for cheque dishonour unsustainable.

Analysis: Sections 118(a) and 139 of the Negotiable Instruments Act, 1881 raise presumptions of consideration and discharge of debt, but those presumptions are rebuttable on a preponderance of probabilities. A probable defence may arise from deficiencies in the complainant's evidence as well as defence evidence. Once the financial capacity to advance the alleged cash loan was specifically challenged, the absence of bank records, receipts, or any financial trail required affirmative proof of capacity and of the underlying transaction. Although a voluntarily delivered signed blank cheque may attract the presumption under Section 139, it does not dispense with proof of a genuine underlying liability after a probable defence is raised. The withholding of a cited eyewitness to the alleged loan and delivery of the cheque warranted an adverse inference under Section 114(g) of the Indian Evidence Act, 1872. The consistent defence evidence, together with these deficiencies, rebutted the presumption; summary answers under Section 313 of the Code of Criminal Procedure, 1973 could not cure the complainant's evidentiary gaps.

Conclusion: The statutory presumption stood rebutted and the alleged legally enforceable debt was not proved; the concurrent findings of conviction were perverse and legally unsustainable.

Issues: Whether ex parte appellate orders passed after the company's winding up, without notice to or hearing through the liquidator, could be sustained.

Analysis: Section 279 of the Companies Act, 2013 provides that pending legal proceedings by or against a company in winding up cannot be proceeded with except with the Tribunal's leave. The provision expressly encompasses proceedings pending on the date of the winding-up order. Following winding up, the liquidator steps into the company's position, and an effective opportunity to prosecute the pending appeals must be afforded through the liquidator. The appellate orders had been passed ex parte without considering the company's case.

Conclusion: The ex parte appellate orders were set aside, and the appeals were remitted for fresh adjudication after notice and personal hearing to the liquidator.

Outcome: The Special Leave Petition was disposed of without interference, with clarification that the Appellate Authority shall decide the case on its own merits.

Issues: (i) Whether the Order-in-Original was barred by limitation under Section 28(9) read with Section 28(9A) of the Customs Act, 1962; (ii) Whether writ jurisdiction should be exercised despite the available statutory appellate remedy and the petitioners' conduct during adjudication.

Issue (i): Whether the Order-in-Original was barred by limitation under Section 28(9) read with Section 28(9A) of the Customs Act, 1962.

Analysis: For a notice issued under Section 28(4), Section 28(9)(b) prescribes a one-year determination period, extendable under its first proviso. Section 28(9A) independently provides that, where an enumerated circumstance prevents determination, the statutory period runs from cessation of that circumstance. The pending writ concerning extension of the export-obligation period and substitution of duty-free inputs, together with the operative interim protection, was directly germane to the customs adjudication and fell within Section 28(9A)(b). The transfer to the Call Book was consequential and did not itself create the statutory exclusion. The noticees had themselves sought deferment on that precise basis and were fully aware of the reason for non-determination; thus, the purpose of the communication requirement stood substantially fulfilled. An administrative Call Book circular could not displace the statutory consequence under Section 28(9A).

Conclusion: The Order-in-Original was passed within the statutory period reckoned from cessation of the circumstance under Section 28(9A)(b); the limitation challenge fails against the assessee.

Issue (ii): Whether writ jurisdiction should be exercised despite the available statutory appellate remedy and the petitioners' conduct during adjudication.

Analysis: Writ jurisdiction under Article 226 is discretionary and equitable, particularly where an efficacious statutory appeal is available. The petitioners did not contest the substantive adjudicatory findings, sought deferment of adjudication because of the pending writ proceedings, reserved a right to file a substantive reply thereafter, and did not communicate the cessation of the circumstance on which deferment was sought. The principle against approbation and reprobation precluded an equitable advantage from the delay occasioned by their own request for deferment.

Conclusion: Extraordinary writ relief was declined against the assessee, who may pursue available merits-based contentions before the statutory appellate authority.

Final Conclusion: The customs adjudication remains legally operative, with the merits of the duty demand open for examination through the prescribed appellate mechanism.

Ratio Decidendi: Where an enumerated circumstance under Section 28(9A) prevents customs adjudication, the limitation period under Section 28(9) runs from cessation of that circumstance; a consequential Call Book entry or administrative circular cannot override that statutory consequence.

Issues: Whether written acceptance of enhanced customs valuation dispenses with a speaking order and precludes the importer from challenging the reassessment and rejection of the declared transaction value.

Analysis: Written acceptance under Section 17(5) is confined to dispensing with the procedural requirement of a speaking order on reassessment; it does not amount to an unconditional waiver of the statutory right to appeal under Section 128 or to contest the legality and merits of the enhancement. Rejection of transaction value requires compliance with Section 14 and Rule 12(2), including written communication of grounds for doubting the declared value. Consent letters referring generally to contemporaneous imports, without disclosure of comparable data concerning quantity, quality and contemporaneity, do not establish a voluntary abandonment of valuation rights. Acquiescence cannot defeat rights conferred by statute, and the ruling concerning mandamus for a speaking order does not bar an appeal challenging reassessment.

Conclusion: Written acceptance waived only the speaking order and did not foreclose the statutory challenge to enhanced valuation; the reassessment and appellate rejection founded solely on such acceptance were unsustainable. The issue is decided in favour of the assessee.

Issues: Whether a warrant of arrest could be issued against accused persons already on bail, without first issuing summons after transfer of the complaint to the Special Court.

Analysis: The accused persons were on bail and had not been given an opportunity to appear before the transferee Special Court. The statutory transfer of jurisdiction to the Special Court did not justify immediate issuance of an arrest warrant. The proper course was to issue summons initially and thereafter adopt lawful coercive measures to secure attendance only if required.

Conclusion: The arrest warrant issued without first serving summons was illegal and was set aside.

Issues: (i) Whether the financial creditor's application under Section 7 was barred by limitation; (ii) Whether the failed revival scheme and pending winding-up proceedings precluded continuation of the insolvency proceedings.

Issue (i): Whether the financial creditor's application under Section 7 was barred by limitation.

Analysis: Although Article 137 prescribes a three-year limitation period from default, the corporate debtor's continuing failure to deliver possession or refund the amounts constituted a continuing breach and subsisting default. The revival scheme also acknowledged the financial creditor's claim, furnishing acknowledgment of liability and supporting extension of limitation.

Conclusion: The Section 7 application was not time-barred; this issue is decided in favour of the respondent.

Issue (ii): Whether the failed revival scheme and pending winding-up proceedings precluded continuation of the insolvency proceedings.

Analysis: The revival scheme had become unworkable and was set aside. The High Court thereafter directed revival of proceedings under the Insolvency and Bankruptcy Code, 2016, and granted liberty to pursue further proceedings before the NCLT. Proceedings under Section 7 operate independently and were not barred by the earlier winding-up and revival-scheme proceedings.

Conclusion: The failed revival scheme and winding-up proceedings did not prevent continuation of the Section 7 insolvency proceedings; this issue is decided in favour of the respondent.

Final Conclusion: The corporate debtor remains subject to the insolvency resolution process initiated on the established debt and default.

Ratio Decidendi: A continuing failure to deliver possession or refund amounts, coupled with acknowledgment of liability, keeps a financial creditor's insolvency claim within limitation despite an earlier default.

Issues: Whether bail should be granted in a money-laundering prosecution despite the restrictions under Section 45 of the Prevention of Money Laundering Act, 2002.

Analysis: The allegations of impersonation, forgery and extortion were serious, and the material did not establish satisfaction of the statutory restrictions ordinarily applicable to bail. However, custody exceeding one year could outweigh the rigours of the twin conditions in an appropriate case. Relevant mitigating circumstances were that bail had already been granted in the predicate-offence case, investigation of that case remained pending, and parts of the material relied on in the money-laundering case concerned matters not necessarily forming part of the predicate offence. The progressing trial and potential risk to witnesses warranted safeguards to secure attendance and protect the proceedings.

Conclusion: The prolonged custody and mitigating circumstances justified grant of bail subject to safeguards for the trial.