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    Plausible explanation for offering income and paying tax led ITAT to delete penalty for alleged cash receipts.
    Real income and tax credit principles led to deletion of expense disallowance and verification of self-assessment tax credit.
    Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
    Embedded profit in on-money receipts taxed at 10%, with income recognised on sale deed execution, not cash receipt.
    Surcharge on private discretionary trusts: ITAT applies Finance Act slab rates and accepts 15% surcharge instead of 25%.
    Provisional release conditions: bank guarantee for seized goods held arbitrary, while appeal maintainability was upheld.
    Ore-to-concentrate conversion defeats CVD exemption where imported manganese has undergone washing, waste removal and sizing.
    Refund claims filed before final settlement of an exemption dispute are premature and may be rejected.
    FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
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    Panchnama and section 9D evidence rules defeat clandestine manufacture demand where manufacturer identity is not proved.
    Promissory estoppel applied to SEZ octroi exemption, making the State liable for refund despite no municipal statutory amendment.
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      Certificates of Origin continue to be treated as instruments...

      Digital-only issuance of Certificates of Origin mandated for authorised agencies, with manual processing barred and revocation risk attached.

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      DGFTApril 8, 2026Circulars
      Certificates of Origin continue to be treated as instruments evidencing the origin of goods imported into any country, and the existing classification into preferential and non-preferential certificates is retained. The list of authorised issuing agencies remains in Appendices 2B, 2C, 2D and 2E. All authorised agencies must now accept applications and issue Certificates of Origin only through the designated electronic platform, currently trade.gov.in, or any other platform DGFT may later designate. Manual issuance outside the prescribed platform is not permitted and may result in revocation of authorisation.

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      ActsIncome Tax