Extended-period reassessment requires recorded reasons to link escaped income to a prescribed asset, transaction-related expenditure, event or occasion, or book entry; unidentified unaccounted receipts or expenses alone do not satisfy that jurisdictional condition, invalidating the challenged reassessments. For the assessment year preceding the search year, a section 143(3) assessment cannot be completed without notice under sections 147/148. Digital material alleging unaccounted sales must demonstrate relevance, authenticity, integrity and probative value, with identifiable completed sales or receipts and independent corroboration. Uncontextualised WhatsApp chats, unrebutted retracted statements, unreconciled seized records, or backward projection of later-year material cannot establish year-specific taxable income or sustain profit estimation.

Transfer-pricing benchmarking under TNMM required royalty for engine technology to remain aggregated with the manufacturing segment once TNMM had been accepted as the most appropriate method; separate royalty benchmarking was deleted for both assessment years. Engineering and design comparability required exclusion of a company with diversified services, no reliable segmental data, a different functional profile and an extraordinary acquisition; margins require recomputation. The expenditure disallowance relating to exempt dividend income was sustained under section 14A read with Rule 8D. Tax liability, credits and interest computations were remitted for verification and correction.

Penalty under Section 271(1)(c) does not follow merely from a Section 43B disallowance where statutory tax liabilities were not claimed as expenditure, were disclosed in the tax audit report, and rested on a plausible interpretation; a quantum addition alone does not establish inaccurate particulars. Foreign dividend income disclosed in Schedule SI and taxed at the applicable special rate is not concealed merely because it was omitted from the computation summary, where the mismatch was inadvertent and rectification was voluntarily sought before revisionary proceedings. Penalties relating to both items were deleted, and the Revenue's challenge failed.

Net profit estimation for a vegetable commission business must reflect the nature of commission activity and available material after cash deposits are accepted as business turnover. Relevant considerations include loading and unloading, salary and administrative expenses, and income results accepted for the succeeding assessment year and another comparable business assessment, without mechanically applying those comparables. Incomplete records and transaction volume do not justify reduction merely on a general claim. Business income was recomputed by applying a 2% net profit rate to accepted business receipts.

Recording satisfaction during assessment proceedings is required before penalty for an alleged cash-receipt contravention of section 269SS can be validly initiated. Applying the Supreme Court principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of any satisfaction or penalty initiation in the assessment order as an invalid assumption of jurisdiction. It deleted the penalty under section 271D without deciding whether section 269SS applied to cash sale consideration for immovable property.

Following a search under section 132, assessment of search-related escaped income must proceed through the special reassessment mechanism under section 148 rather than the general scrutiny-assessment route under section 143(3). Consequently, a regular assessment made under section 143(3) for the relevant post-search assessment was treated as unsustainable in law and quashed, rendering the remaining grounds academic. The principle limits recourse to ordinary scrutiny assessment where the prescribed search-linked reassessment framework applies.

Section 50C does not extend to relinquishment of an unregistered contractual right to seek specific performance of an agreement to sell land. Where no sale deed is registered in the transferee's favour and the vendor remains owner, the relinquished right is a capital asset comprising a contractual remedy, not land or building. The deeming fiction is confined to transfers of land or building and cannot be enlarged to cover such rights. A registered leasehold interest was distinguished because it confers possessory and enjoyment rights in rem. The recomputation of long-term capital gain under section 50C and the resulting addition were deleted.

Jewellery found in an assessee's locker was treated as explained where government-approved valuation reports established its age and ownership by the assessee and family members. CBDT Instruction No. 1916 serves as a guiding consideration for jewellery attributable to family members, assessed with reference to family status, customary gifts and inheritance, and the surrounding circumstances. On these facts, the explanation of source was accepted and the addition for unexplained jewellery was deleted.

Investigation material linking three loan creditors to accommodation-entry providers, supported by admissions concerning management of bank accounts and income-tax files, established a sufficient nexus for reassessment; the challenge to reopening failed. Confirmations and bank records showing full repayment in the following financial year, together with no corresponding addition for loans from the same creditors in the succeeding year, meant the loans could not be treated as accommodation entries. The Tribunal deleted the bogus-loan addition, and the consequential unexplained-expenditure addition did not survive; the appeal was partly allowed.

Foreign salary earned by a non-resident and received in USD in an NRE account requires assessment of evidence establishing foreign employment, non-residential status, and receipt of salary. Passport entries, employment records, and NRE account details are material evidence and should be considered. The absence of foreign tax returns, a tax residency certificate, or proof of foreign tax payment does not alone warrant rejection of the claim where available records support it. Assessment should address these documents without treating foreign tax records as a mandatory condition.

BSE futures and options trade profits disclosed for tax were supported by contract notes, tax records, bank statements, annual reports, transaction statements and account confirmations. Treating those profits as unexplained cash credit requires material showing that the broker or counterparty was tainted; no such material was identified. The preponderance-of-probabilities assessment distinguished alleged pre-arranged reversal trades involving loss-making entities from profitable trades with no identified loss-making counterparty. The trades were accepted as genuine, resulting in deletion of the unexplained cash credit addition and the consequential alleged commission expenditure addition under Section 69C.

Penalty notices for concealment or furnishing inaccurate particulars must specify the exact charge and remove the inapplicable alternative; retaining both charges invalidates initiation. Similarly, search-penalty notices for undisclosed income must identify the applicable statutory clause because alternate clauses impose distinct conditions and consequences; non-specification makes the proceedings defective. Salary expenditure disallowed as allegedly non-genuine services was treated as requiring fact-based inquiry, but the related additions were restricted to 10% with consequential relief. Penalties based on defective notices were untenable.

The Faceless Penalty Scheme SOP assigns Chapter XXI penalty proceedings to the Penalty Unit. Once the Penalty Unit became operational, the transitional arrangement allowing the Assessment Unit to act as the Penalty Unit ceased to apply. Accordingly, the Assessment Unit lacked jurisdiction to impose penalties under section 271D for alleged cash contributions accepted from members. Penalty orders issued by the Assessment Unit after operationalisation of the Penalty Unit were quashed for want of jurisdiction, rendering the remaining grounds academic.

Agreement-date stamp-duty valuation under section 56(2)(vii)(b) is available only where a pre-registration agreement fixes the consideration for the property ultimately registered and the prescribed non-cash payment condition is met. An earlier booking for a different flat with an erstwhile developer does not meet those requirements where the registered agreement concerns a new flat and a new developer, absent a legally established linkage between earlier payments and the later consideration. The stamp-duty value applicable to the subsequently registered transfer therefore governed the addition for the difference in value.

Re-import exemption for an Indian-registered personal vehicle returning from travel abroad is not defeated by the absence of Section 51 export clearance where it lawfully left as a private conveyance under Chapter VI; containerisation for safe transit does not make it commercial cargo. Where electronic Bill of Entry filing is impossible because the owner lacks IEC or GSTIN, filing without those identifiers, including manual filing, must be permitted. Release remains subject to the prescribed bond, verification of claimed export benefits or drawback, and cooperation in adjudication.

Reverse burden of proof for notified gold is discharged when the carrier produces a delivery challan supporting lawful possession. The evidential burden then shifts to Revenue to prove foreign origin and smuggling. A town seizure, gold purity below 99.9%, and procurement records corroborated by GSTR-2A did not establish reasonable belief that the gold was smuggled. On those facts, confiscation was set aside and release of the gold was directed.

Beneficial owners exercising effective control over imported goods may be treated as importers and held liable for customs duty, interest, penalty and fine, including authorised signatories acting under powers of attorney for a deceased sole proprietor. Transaction value cannot be rejected merely on NIDB data unless evidence establishes that the declared price was not the price actually paid or payable, supported by comparable-goods analysis. Where quantity misdeclaration is admitted, duty may be recovered on undeclared goods at the declared value. Findings on live consignments cannot, without proof of undervaluation, justify enhancing assessable value of past cleared consignments or confiscating them. A substantial non-bona-fide quantity discrepancy may sustain penalty under Section 114AA, although other penalty and confiscation directions may fail.

DHA algae oil, when imported as an edible algae oil consisting of a mixture of saturated and unsaturated fatty acids, is classified under Chapter 15 rather than as a separate chemically defined unsaturated fatty acid under Chapter 29. Under the General Rules of Interpretation, classification follows the tariff headings and relevant Chapter Notes; the presence of DHA or food-industry use does not alter that result. Chapter 21 does not describe oils. Classification under Chapter 15 precludes the claimed notification benefit and sustains consequential differential duty, interest and penalties for misclassification.

Optical transceivers that convert optical signals into electrical signals and vice versa, functioning only as network interface modules, are components or parts of Optical Transport Network products rather than complete Optical Transport Network products. They do not perform complete system functions such as OTN framing, multiplexing, forward error correction or operations, administration and maintenance. Classification therefore falls under CTI 8517 7090 rather than CTI 8517 6290. Because the customs exemption exclusion applies only to complete Optical Transport Network products, it does not cover these transceivers. The claimed exemption benefit remains available, and the Revenue's appeals were dismissed.

Company-name rectification under Section 16(1)(b) turns on whether the impugned name is identical with or too nearly resembles a registered trade mark, without requiring proof of likely deception or confusion. Competing names must be compared holistically, including phonetic and structural similarity, rather than by separating individual components. Applying that approach, "TOPLAD" was found too nearly to resemble "TOPLAND"; omitting "N" did not create sufficient visual or phonetic distinction for an Indian consumer of average intelligence. The rejection of rectification was set aside, and adoption of a non-resembling company name was required.