JCB India targets 15-20 per cent export growth during the current financial year and plans a similar increase in annual production. Its export operations cover approximately 135 countries, including Southeast Asia, Africa and developed markets. The company's construction and earthmoving equipment portfolio is designed, engineered and manufactured in India for domestic and international customers, with product development focused on fuel efficiency, operator ergonomics, comfort and productivity.

Roasted areca nuts, whether whole, split or cut, fall under Tariff Item 2008 19 20 as other roasted nuts and seeds. Roasting causes chemical and physical changes and is distinct from drying, dehydration, moderate heat treatment, and permitted preservation or appearance treatments for dried nuts under Chapter 8. Chapter 20 is not excluded because roasting is not a process specified in Chapters 7, 8 or 11. HSN Explanatory Notes to Heading 2008 expressly cover dry-roasted, oil-roasted and fat-roasted areca or betel nuts; the specific entry for roasted nuts and seeds prevails over the general Chapter 8 description.

Alternative appellate remedies do not absolutely preclude writ review under Article 226, as the exhaustion rule is based on policy, convenience and discretion. Writ jurisdiction is available where the decision-making process fails to consider material evidence relevant to the seizure's foundational basis. In customs proceedings, an expert report indicating that seized areca nuts resembled Indian goods required consideration alongside a food laboratory report on human-consumption fitness. An undertaking against human consumption addressed the food-safety concern, making continued detention and refusal of provisional release unsustainable. Provisional release should be granted through the statutory mechanism where material expert evidence has been disregarded.

Reassessment notice limitation for assessment year 2014-15 expired under the pre-amendment six-year period on 31 March 2021. Under the Supreme Court framework governing the amended reassessment regime, TOLA and the deemed-notice procedure, only the balance period up to 30 June 2021 remained available after completion of the section 148A process. A notice issued on 27 July 2022 therefore fell outside the surviving limitation period, rendering it time-barred and void from inception. Reassessment proceedings founded on that notice were invalid.

House-property loss claimed for a multiplex requires examination of completion and occupancy certificates and related evidence before determining whether the building remained under construction. The issue requires fresh adjudication after reasonable opportunity of hearing. Belated employees' provident fund contributions are not allowable under the Supreme Court principle applied in Checkmate Services Pvt. Ltd.; the related disallowance remains undisturbed. Completion and occupancy evidence therefore governs reconsideration of the house-property loss, while delayed employee provident fund payments continue to be disallowed.

Demonetised currency received by a recognised LIC premium collection agent from clients for payment of LIC premiums could not be assessed as the agent's unexplained income. Where premium payments in demonetised notes were permitted during the relevant period and the agent handled the collections solely on LIC's behalf, with no finding of personal use, the receipts retained their agency character. The addition treating those collections as unexplained income was deleted.

Section 153D requires separate approval for each assessee and each assessment year in search assessments. A consolidated, mechanical approval covering multiple assessees and assessment years does not meet this statutory requirement and is invalid. Consequently, search assessment proceedings founded on such approval are liable to be quashed, favouring the assessee.

Unexplained cash-credit addition was sustained because bank credits claimed as rental income were unsupported by a rental agreement, tenant particulars, property details, or other evidence establishing their nature and source. Rental receipts disclosed from a different entity did not substantiate the separate credits under examination. The failure to produce documentary support at the appellate stage left the asserted rental-income explanation unproved, resulting in the credits being treated as unexplained.

Disclosed agricultural income accepted by the Revenue for the relevant and immediately preceding years can explain the source of cash deposited in a bank account. A deposit made during the demonetisation period does not, solely because of its timing, become unexplained money. Where accepted agricultural income supports the availability of cash, the deposit cannot be assessed as unexplained money and is treated as satisfactorily explained.

Reopening based solely on survey material already available to the Assessing Officer cannot be used to reappraise matters for which scrutiny could previously have been initiated. For Assessment Year 2012-13, reassessment initiated after four years without fresh tangible material constituted an impermissible review and was void. For Assessment Year 2013-14, reopening of a completed scrutiny assessment also required proof of income escapement and failure to make a full and true disclosure of material facts. As the reasons merely revisited examined material and showed neither requirement, the reassessment was invalid as a change of opinion.

Material seized during a search of another person triggers the statutory framework for third-party search assessments under Section 153C. An ordinary assessment under Section 143(3), even where the assessee's case was centralised on the basis of such material, does not meet that framework and is invalid. Selling expenditure comprising commission and miscellaneous expenses cannot be wholly disallowed on the stated facts; the claim may be restricted where warranted. The selling-expense disallowance was limited to 10%, with the balance allowed.

Tax deduction at source under section 195 applied to a payment made to a non-resident because the payment, as confirmed in earlier appellate proceedings, was for non-technical value and did not fall within the specified category of payments not chargeable to tax. No contrary material displaced the findings supporting the payer's default. Consequently, tax was required to be deducted on the non-resident payment, and the finding of default against the assessee remained sustained.

Section 68 requires an assessee to establish investors' identity, financial capacity and the genuineness of share capital and share-premium transactions. The shareholders did not independently respond to notices, and the assessee did not provide adequate material on major investors' financial capacity or sources of investment. It also failed to explain the valuation and basis for the substantial share premium. One investor's disclosed income was disproportionate to the investment, while documentation for other investors was inadequate. Consequently, the assessee did not discharge its evidentiary onus, and the addition for unexplained share capital and share premium remained sustained.

Event-management budgets recorded as matching revenue and expenditure entries do not create taxable income or deductible expenditure where the assessee neither received nor paid the budgeted amounts. Where actual income is limited to a management fee and bank records show no movement of the gross budgeted sums, taxation must be based on real income. Disallowing the corresponding notional expenditure while retaining the matching notional revenue would misread the accounting disclosure and tax unreal income. The budgetary entries therefore cannot support a disallowance.

Long-term capital gains exemption on share sales requires reconsideration where the initial deletion rested on an absence of investigation or adverse material, but subsequently produced material may affect that factual premise. Its merits and evidentiary value require examination after hearing both sides. Income arising under a real-estate collaboration agreement also requires fresh review where the treatment of receipts did not assess the transfer of development rights and land held as stock-in-trade as an integrated transaction. Revenue recognition and the relevant factual material must be evaluated before either addition is sustained or deleted.

Payments to a Singapore non-resident for Turnitin and iThenticate software solutions were not royalty under the India-Singapore DTAA where distribution arrangements granted no interest in, or right to use, the software copyright. The payments related to software supplied for resale to Indian distributors or end-users and did not constitute consideration for use of copyright. As no income taxable in India arose, no tax deduction at source obligation applied, and the related disallowance for non-deduction was deleted.

Section 69A permits an addition for unexplained money where the assessee does not satisfactorily explain its source. Cash deposits were explained as arising from earlier withdrawals from salary and Kisan Credit Card accounts. Bank statements and Kisan Credit Card records substantiated those withdrawals, while the salary income and the existence of the credit account were undisputed. The documented withdrawals made the stated source of the deposits plausible, supporting deletion of the addition for unexplained cash deposits.

Reassessment notice under Section 148 for assessment year 2014-15 was required to be issued by 14 June 2022 after applying the surviving limitation period under the transition to the new reassessment regime. The notice issued on 25 July 2022 was therefore time-barred. Consequently, the reassessment proceedings and resulting reassessment order were void from inception and liable to be quashed.

Foreign tax credit is not denied solely because Form 67 was filed after the due date under Section 139(1) of the Income-tax Act, 1961. The time requirement for filing Form 67 is directory rather than mandatory; therefore, delayed compliance does not by itself defeat entitlement to credit for foreign taxes. Credit remains subject to verification of the relevant facts and computation.

Statutory appellate remedy was available for challenges to a show-cause notice and consequential order, including objections concerning jurisdiction, mechanical adjudication and breach of natural justice. Those grounds were capable of examination through the prescribed appeal mechanism, without any opinion on their merits. The writ petition was disposed of with liberty to pursue the statutory appellate remedy.