Search assessment and multiplex lease receipts: incriminating material limits additions, but commercial exploitation supported business income treatme...

Reassessment by change of opinion fails where reopening rests on the same records and an incorrect factual premise.

Limited scrutiny assessment cannot support additions beyond selected issues without conversion to complete scrutiny.

Turnover filter and functional comparability in software transfer pricing upheld; limited comparables can still support arm's length benchmarking.

Unsubstantiated commission-agent claim rejected; profit estimation from bank credits cut from 12.5% to 4% in trade income case.

Diversion of income by overriding title shields liquidation receipts from tax where statutory application diverts realizations at source.

Make available condition under the India-Netherlands treaty defeated FTS taxability; surcharge and cess beyond treaty rate were disallowed.

Pre-deposit under customs appeals: filing and registration are allowed first, while entertainment can be withheld until deposit is considered.

Anti-dumping duty time limit under Rule 18 expired, so final findings could no longer be acted upon.

Transaction value for used machinery cannot be rejected on an unsupported local valuation when contemporaneous import evidence is unrebutted.

Customs Broker penalty for alleged overvaluation abetment set aside absent proof of knowledge or involvement.

Customs penalty fails without admissible proof of conscious involvement, as untested statements and bare allegations cannot sustain abetment findings.

Town seizure of gold and silver fails without reasonable belief, foreign origin proof, or rebuttal of domestic purchase records

Bona fide transferee protection for re-registered duty-free licences: customs demand and extended limitation were set aside.

Locus to challenge Section 7 admission upheld where alleged loan was found to be a sham financial transaction.

Moratorium adjustment and fraudulent trading claims remanded after material lease documents were not properly considered.

Resolution plan approval under CIRP cannot be rejected on vague fairness concerns where statutory compliance and disclosure are established.

Liquidation estate and title disputes: NCLAT held third-party cotton bales were excluded, leaving related remedies to the proper forum.

Pre-CoC CIRP withdrawal upheld where Form FA was routed through the interim resolution professional within Regulation 30A procedure.

Bank account freezing without lawful authority was arbitrary; anti-money laundering reporting rules did not justify de-freezing refusal.