Minimum Import Price restrictions regulate imports entering the domestic market for home consumption and do not apply to goods warehoused under Customs control exclusively for re-export. A declared value below the Minimum Import Price, or higher National Import Database data alone, does not establish undervaluation without corroborative evidence of under-invoicing, additional consideration, or deliberate misdeclaration. Where the Minimum Import Price premise does not apply, rejection and redetermination of declared value cannot survive. The declared assessable value was restored, consequential confiscation, redemption fine and penalty were set aside, and re-export was permitted subject to procedural requirements.

Pine Bark Extract and Grape Seed Extract are classified as vegetable extracts under Heading 1302 rather than as food preparations under Heading 2106. Multi-stage extraction, concentration, drying, or adsorption does not exclude goods from Heading 1302 unless processing selectively enriches or depletes particular compounds or compound classes beyond ordinary solvent extraction. As single-ingredient botanical extracts imported in bulk as raw materials, the products were not finished food or dietary supplements for direct consumption. Because neither product was specifically enumerated within Heading 1302, both fall under the residual tariff item for other vegetable extracts, Customs Tariff Item 1302 19 39.

Pendency of arbitration over underlying loan transactions does not prevent initiation of wilful-defaulter proceedings where borrowers are alleged to have disposed of assets securing credit facilities without lender approval. Such alleged conduct falls within the RBI Directions, 2024, and a show-cause notice founded on identified assets and supplied documentary material represents only a prima facie view. Borrowers must respond before the competent committees decide the matter and may use the available review process thereafter. The challenge was treated as premature; the notice remained in force and the response period was extended by two weeks.

Greenhouses cleared from the factory in ready-to-assemble condition fall under the specific tariff entry for greenhouses in ready-to-assemble sets rather than the general entry for plant growth chambers, applying Rule 3(a)'s preference for the most specific description. An amendment extending the normal excise-demand limitation period from one year to two years operates prospectively absent express retrospective effect and cannot revive a demand already time-barred. On that limitation basis, the duty demand, interest and penalty were set aside.

Portfolio-management reforms replace the 2020 framework and expand investments into IPOs, primary-market debt, listed overseas equity and debt, and direct plans of Indian mutual fund schemes. Investment-grade unlisted non-convertible debt may comprise up to 10 per cent of client assets under management with client consent. Independent Fund Managers may operate with registered portfolio managers, which retain responsibility and liability. Accredited-investor eligibility is broadened, while specified compliance requirements are relaxed where adequate audit trails and internal controls exist.

GST treatment of MDR charged on UPI merchant payments above Rs 2,000 is to be considered by the GST Council. The MDR framework imposes a merchant-borne charge for payment processing and settlement. As these activities are services, MDR may attract GST at 18 per cent, subject to the Council's view. Merchants paying GST on MDR may claim input tax credit, potentially reducing their net tax burden.

Finance-department advice treats fiscal indicators as grounds for restraint in approving additional expenditure rather than as evidence that funds are unavailable. Funding new projects may be difficult until additional resources are mobilised or allocations already approved are reallocated. Project proposals lacking budgetary provision or earmarked funding may create cash-flow pressures and fiscal-management challenges, requiring deferment until resources are finalised.

Amounts deposited during customs investigation under protest retain their character as investigation deposits when the related duty demand is annulled, despite later appropriation. They are distinct from statutory appellate deposits under Section 129E; consequently, Section 129EE's notified 6% interest rate does not govern them. Where no statutory rate applies, entitlement to restitutionary interest depends on applicable binding judicial precedent. Jurisdictional precedent supported 12% interest on the refundable investigation deposit, while confining the 6% rate to amounts actually deposited under Section 129E. Section 27's protest exception and Section 27A's delayed-refund framework require separate assessment according to the payment's legal character.

Section 31 finality under the IBC requires approved resolution plans to determine the treatment of operational-creditor claims and bind all stakeholders. Although Section 3(6) permits disputed and unadjudicated payment rights to enter CIRP, such inclusion does not by itself preserve related civil or arbitral proceedings after plan approval. Claims recorded at a notional value must be read with the final creditor list, distribution provisions, release clauses, cut-off dates and any express preservation mechanism. Unquantified pre-plan liabilities and proceedings are extinguished where the plan provides for discharge and abatement; a payment pool does not reserve funds for them without express terms. Section 238 gives this framework primacy over inconsistent remedies.

GST registration may be cancelled for continuous non-filing of returns under Section 29, but cancellation does not extinguish pre-cancellation tax liabilities. Rule 22 requires notice and an opportunity to respond; where pending returns are filed and tax, interest and late fee are fully paid before cancellation, the officer must drop proceedings. Post-cancellation revocation under Rule 23 requires compliance with prescribed filing, payment and limitation conditions, while appellate authorities cannot exceed statutory condonation limits. Defective notices, absence of reasons, denial of meaningful hearing, or unexplained retrospective cancellation may invalidate the process. Conditional restoration may be available in appropriate non-fraud cases upon full regularisation of returns, tax, interest, late fee and penalty.

Article 8 of the India-UK DTAA confines treaty protection to profits from international aircraft operations, qualifying pool participation, and activities directly connected with the enterprise's own transportation. Engineering and ground-handling services supplied to other airlines constitute taxable third-party commercial service income where they lack that direct nexus and do not arise from a qualifying pool. An IATP arrangement requires evidence of its substantive pooling character, including applicable arrangements and reciprocal operations; its label or aviation-related nature is insufficient. Treaty-specific wording controls: provisions in other DTAAs concerning pools, joint businesses or reciprocal facilities cannot expand the India-UK definition, and OECD commentary cannot override an express treaty definition.

Section 143(2) requires a notice to be served within the statutory limitation, communicate scrutiny, and require attendance or evidence supporting the return. CBDT-prescribed scrutiny formats bind departmental authorities administratively, but non-use does not itself create a jurisdictional defect where the notice otherwise meets statutory requirements and no actual prejudice is established; Section 292B may cure formal defects. Section 292BB separately addresses objections to service, timeliness, or manner of service. Limited scrutiny remains confined to selected issues unless prescribed conversion safeguards are followed, and a later information notice cannot validate unauthorised expansion. Format non-compliance may nevertheless entail administrative accountability.

Extended limitation under Section 74 applies only where unpaid or short-paid tax, erroneous refund, or wrongly availed or utilised input tax credit is attributable to fraud, wilful misstatement, or suppression of facts intended to evade tax. Audit under Section 65 and return scrutiny under Section 61 are distinct processes, and either may lead to proceedings under Section 73 or Section 74. A prior audit-based proceeding does not automatically bar a later Section 74 demand founded on a materially distinct discrepancy in return or reconciliation data. The notice must specify its factual grounds, and duplication must be assessed by comparing the factual basis, periods, source material, and legal allegations.

Pre-notice payment of the entire reverse-charge service-tax liability bars a recovery notice for that amount under the Finance Act, 1994. Following introduction of the negative-list regime, service descriptions no longer determine tax liability. Therefore, an incorrect service category in an ST-3 return does not by itself establish non-payment where the tax has been credited to the Central Government. Tax paid under an incorrect category may be adjusted against reverse-charge tax on services actually received, avoiding a fresh service-tax demand.

Cash payments for agricultural produce purchased directly from farmers fall within the Rule 6DD(e)(i) exception to cash-payment disallowance where direct purchases are supported by farmers' confirmations and land records. Accordingly, such payments are not subject to disallowance under Section 40A(3). Gross-profit estimation based on the average gross-profit rate of earlier years remains undisturbed where no basis exists to alter that estimation.

Ad hoc disallowance of site-wage expenditure requires an evidentiary basis showing that the claimed wages are excessive, non-genuine, or unsupported. Cash payments and alleged gaps in supporting details do not, by themselves, justify disallowance where signed wage registers, worker identification, cash-withdrawal reconciliations, and project-site transfer records support the expenditure. Comparable profit-margin material and remand verification must disclose a specific defect before an estimated disallowance can be sustained. On these facts, deletion of the ad hoc disallowance of site wages was justified.

Approval under Section 151 of the Income-tax Act must be granted by the statutorily competent authority before reassessment proceedings may validly commence. Sanction from an authority lacking statutory competence creates a fatal jurisdictional defect. Reassessment founded on such invalid approval is invalid and subject to quashing because the required precondition for jurisdiction remains unmet.

Section 69A addition for an alleged bogus entry was deleted where banking records established receipt of an interest-free unsecured loan, the lender confirmed the advance, and the entire amount was repaid through banking channels in instalments. The documented receipt, lender confirmation, and repayment substantiated the loan transaction, preventing its treatment as unexplained money.

Transfer-pricing benchmarking requires non-operating other income to be excluded when applying an ITES service-income filter. A company whose operating service revenue is entirely from ITES may remain comparable, while expenses directly attributable to rental income, including relevant depreciation and property costs, must be verified and excluded from operating expenses when calculating the Profit Level Indicator. Functional comparability of an outsourced publishing-services provider is determined primarily from its own annual-report profile; group-level prospectus descriptions do not establish high-end content, product-development, or knowledge-process functions.

Sections 250(6) and 251 of the Income-tax Act require the Commissioner (Appeals) to determine the points arising from an assessment order through a written, reasoned decision. An assessee's non-participation does not remove the appellate authority's statutory duty to adjudicate the grounds on their merits. The Commissioner (Appeals) cannot summarily dismiss an income-tax appeal for non-prosecution and must pass a speaking order after providing appropriate opportunity.