Transfer-pricing treatment of intra-group management and technical services requires evidence that services were rendered, availed and commensurate with the charge, including agreements, allocation methodology, invoices and correspondence. Commercial expediency remains the taxpayer's business judgment: the TPO cannot replace it or insist on immediate benefits, and an arm's length price should not be fixed at nil where evidence supports the services. For outstanding associated-enterprise receivables, interest is benchmarked at LIBOR plus 200 basis points after a 60-day credit period, requiring recomputation on that basis.

Intra-group management and IT support charges could not be wholly rejected where associated enterprises provided services, but debit notes, allocation bases and allocation keys were necessary to verify the charges. The ad hoc restriction was improper, and the issue was remitted to the Assessing Officer/Transfer Pricing Officer for fresh examination. Interlinked trading imports and manufacturing sales required entity-level transfer pricing benchmarking because overseas associated enterprises lacked reliable comparable and complete financial data, while subsequent manufacturing operations made separate segmental RPM or TNMM analysis inappropriate. Those issues were remitted for fresh determination. The Revenue's challenge to allowance of agronomy expenditure was dismissed as covered in favour of the assessee.

Software sub-licensing was treated as provision of services rather than wholesale trading for transfer-pricing tolerance purposes. With four comparable companies in the final dataset, Rule 10CA(7) applied, and the one per cent variation reserved for wholesale trading did not apply because the activity neither involved goods trading nor met inventory conditions. The difference between the arm's length price and transaction price fell within the applicable three per cent range, so the transfer-pricing adjustment was deleted and benchmarking and comparable challenges required no decision. Claimed TDS short credit requires record verification and allowance in accordance with law.

Notice to a mortgagee bank in benami attachment proceedings was not treated as defective where the bank knew of the adjudication, could approach the Adjudicating Authority, and failed to show prejudice; its challenge to confirmation of attachment therefore failed. Secured-creditor priority under SARFAESI did not require release of mortgaged benami property, because attachment serves prospective confiscation rather than government-debt recovery. The bank was required to seek recovery from other mortgaged securities first and could make a statutory claim if any dues remained unrecovered. The attachment remained confirmed.

Statutory limitation on customs demands restricts the Department from initiating or enforcing a fresh demand, but does not bar settlement-stage appropriation of differential duty voluntarily deposited for earlier imports. Where liability is admitted and the deposit is neither retracted nor controverted, it may be adjusted against that liability. Judicial review of a settlement order remains confined to jurisdictional error, denial of natural justice, manifest legal error, or findings unsupported by the record; it does not permit reappraisal of unchallenged factual findings. The voluntary-duty appropriation therefore remained undisturbed.

Writ jurisdiction ordinarily should not bypass the customs appellate mechanism where an effective further statutory remedy exists and resolving the challenge requires examination of disputed facts or merits. Mandatory pre-deposit is a condition for entertaining the statutory appeal and is not ordinarily avoided through a writ petition merely on financial-hardship grounds. Alleged denial of cross-examination and challenges to evidence, penalty legality, or adjudication generally belong before the competent appellate forum when inseparable from the merits. The petition was dismissed without merits review, with liberty to pursue the available appellate remedy and all merits issues left open.

Fair opportunity to a non-party affected by insolvency proceedings requires consideration of its pending intervention application before final adjudication of the Section 7 company petition. The application under Section 60(5) alleged collusive initiation of insolvency proceedings and asserted potential effects on the applicant's rights and property. In the stated circumstances, judicial fairness required the Tribunal to determine that application first because no compelling urgency justified finalising the insolvency petition while it remained pending. The Tribunal was directed to decide the application within three months, if not already decided, and thereafter determine the insolvency petition on merits.

Investigation statements relied upon for clandestine-clearance allegations require compliance with the statutory relevancy procedure, including examination-in-chief and an opportunity for cross-examination; untested statements cannot reliably support a duty demand. Computer-generated data and printouts from CPUs or pen drives require satisfaction of statutory evidentiary conditions and the prescribed certificate before admission. Clandestine manufacture and removal must also rest on tangible, independent corroboration, such as evidence relating to production capacity, raw-material procurement, buyers, transport, labour and electricity consumption. In the absence of admissible statements, compliant electronic records and corroborative material, the clandestine-clearance charge, duty demand and consequential penalties were set aside.

Anti-dumping duty on wind turbine gear boxes containing castings is confined to the castings, rather than the gear boxes as complete equipment. Notification No. 42/2017-Customs (ADD) covers castings in raw, finished or sub-assembled form, including castings forming part of a sub-assembly, equipment or component. The Tribunal's unchallenged interpretation that the levy applies only to the castings within such equipment bound Customs authorities. Consequently, anti-dumping duty could not be imposed on the gear boxes as a whole; the assessment was set aside to that extent, with acceptance of self-assessment and release of related securities.

Customs Broker licence revocation, security forfeiture and penalty require proof of established statutory breaches, rather than apprehension of future misconduct. An importer's authorisation and prescribed KYC records satisfy authorisation and verification duties where the broker files documents supplied by the importer. A discrepancy in goods or brand particulars that emerges only on physical examination does not establish a failure of due diligence. Speed-and-efficiency obligations do not require BIS certificate verification, and cooperation in the investigation defeats a non-cooperation allegation. As the alleged breaches were unproved, the revocation, forfeiture and penalty were set aside.

Customs valuation of imported rechargeable batteries requires stated grounds creating reasonable doubt before the declared transaction value can be rejected. Valuation must then proceed sequentially under the prescribed methods, supported by contemporaneous import data or valid comparison with identical or similar goods; retail market-inquiry prices alone do not justify enhancement. Payment of differential duty for provisional release does not constitute acceptance of the enhanced value or bar challenge. Where the declared invoice amount was remitted and no evidence showed additional payment, quantity or description discrepancies, misdeclaration, fraud, suppression or wilful misstatement, confiscation, redemption fine and penalty lack foundation. The valuation enhancement and consequential duty demand were unsustainable.

For insolvency appeals, statutory limitation remains strict and the Tribunal cannot condone delay beyond the prescribed outer period. Limitation does not run, however, while the filing forum is unavailable or incapable of receiving filings. A bona fide attempt to e-file within time that fails solely because the Tribunal's OTP delivery system malfunctioned warrants exclusion of the non-functional period under actus curiae neminem gravabit, with the initial attempt treated as the presentation date. The time-bar dismissal was set aside and the appeal, with its delay-condonation application, was restored for reconsideration, subject to sufficient cause.

Provident-fund and gratuity dues are excluded from the liquidation estate and cannot be distributed through the insolvency waterfall; a successful resolution applicant must discharge those dues, including statutory interest on arrears. Statutory interest compensates delayed contributions, whereas damages for delay are penal in nature. The expression "may recover" in Section 14B raises whether the authorised officer may decline to impose damages in extenuating circumstances, despite no requirement of mens rea or actus reus; that issue stands referred to a larger Bench. A successful resolution applicant may seek Central Board reduction or waiver of damages, treating resolution-plan implementation as comparable to rehabilitation.

Pre-existing dispute over an outcome-based professional fee may prevent Section 9 insolvency proceedings where contemporaneous correspondence shows a substantive contest about contractual success, fee entitlement, and finality of the underlying GST proceedings. Setting aside of the GST order relevant to fee computation, questions about the capacity in which representation was provided, and the enforceability of relief-linked remuneration under the applicable professional framework may require adjudication outside the limited Section 9 process. A bona fide dispute, rather than a patently feeble defence or later-created contention, leaves the contractual claim to other remedies.

Section 6(3) of FEMA continued to govern foreign-remittance contraventions committed while it was in force despite its subsequent omission. Delayed reporting of foreign investment and delayed share allotment constitute civil regulatory breaches for which liability does not require mens rea unless the statute so provides; later compliance and claimed bona fides do not make the defaults technical. Confiscation under FEMA is discretionary and additional to monetary penalty, requiring a fact-based judicial assessment, including misuse of remittances in a restricted real-estate sector. Director liability depends on responsibility for company affairs: liability does not attach without proof of control, but may attach where managerial responsibility, knowledge, or lack of due diligence is established.

Scheduled-offence status under the Prevention of Money Laundering Act depends on an underlying offence and is necessary to establish proceeds of crime and support a money-laundering investigation. Section 2(2) extends a Central enactment listed in the Schedule to its corresponding law applicable in Jammu and Kashmir. Although Section 13(1)(d) of the Central Prevention of Corruption Act was omitted, amended Section 7 continues to cover obtaining an undue advantage through abuse of official position or corrupt or illegal means. Criminal misconduct under Section 5(1)(d) of the J&K Act therefore remained a corresponding scheduled offence, sustaining Enforcement Directorate jurisdiction to register an ECIR and issue summons.

Contractual self-help repossession of a hypothecated vehicle remains subject to fair-recovery safeguards, including prior notice, an opportunity to cure default, peaceful possession and a transparent sale process. A repossession clause permitting possession without notice, unrestricted entry to locate the vehicle, unspecified recovery or sale procedures, and unilateral waiver of notice cannot validate recovery outside those safeguards. Night-time removal by breaking a steering lock without a possession memorandum, and without the stipulated notice, constitutes unauthorised and arbitrary recovery. Delay alone cannot defeat a challenge where criminal remedies were promptly pursued and no prejudice is shown. Arbitrary repossession of a livelihood vehicle may justify restorative and compensatory relief, although a completed sale may remain undisturbed.

United States sanctions bill concerning Russia would authorize the President to impose sanctions on Russia and punitive tariffs of up to 100 per cent on nations importing Russian crude oil. The tariff mechanism may affect oil and gas trading partners, bilateral relations and global energy markets, with concern expressed over its implications for energy trade.

Congressional legislation targeting Russia and Iran would authorise sanctions against Russia's leadership, energy sector, and vessels facilitating evasion of oil-delivery restrictions. It would also permit punitive tariffs of up to 100 per cent on leading trading partners continuing to import Russian oil and gas. India has identified possible effects on bilateral economic relations and the international energy market, while maintaining that diversified sourcing is necessary for energy security and that its trade and economic interests will be protected.

Validity of the reappointment is therefore contested under the company's internal governance framework despite the majority board vote, and the appointment is expected to be considered for ratification at the annual general meeting. The dispute also concerns the distinction between shareholder influence and directors' decision-making duties. A Trust sought to direct its nominee director to oppose a listing, but the director declined on the basis of independent director duties.