Interest paid on import duty is refundable where an importer initiated timely payment but an ICEGATE technical failure delayed reflection of the Electronic Cash Ledger credit. Section 47 of the Customs Act and the Customs (Waiver of Interest) 3rd Order support waiver in such circumstances. The advisory acknowledging continued portal inability until 27 July 2023 establishes that the delay arose from system malfunction rather than importer default. The waiver remains available even where Bills of Entry were filed after 13 April 2023, provided the delayed payment reflection resulted from the portal failure.

Regulation 20(1) of the Customs Brokers Licensing Regulations, 2013 requires a written initiating notice within 90 days of receipt of an offence report. The initiating notice did not disclose the report's receipt date. Departmental knowledge of the alleged contraventions existed no later than adjudication of the related customs notice on 9 September 2015, making the initiating notice issued on 11 March 2016 beyond the mandatory period. The time limit cannot be disregarded because the allegations may otherwise be sustainable on merits; delayed proceedings are vitiated and the penalty cannot survive.

Combined vehicle radio-receiver/DVD units fitted in a common housing are composite machines governed by Note 3 to Section XVI, requiring classification by principal function. Principal function must be established from the machine's nature, construction and working; promotional material alone is insufficient. Reclassification to video-reproduction apparatus requires cogent technical evidence, including relevant construction, circuitry, component allocation or functional capability. Where principal function cannot be determined, the equally meriting headings are resolved under the last-in-numerical-order rule, supporting classification under CTI 8527 29 00. Failure to establish a contrary classification preserves the declared classification and the related customs-notification benefit.

Non-notified betel nuts do not attract the reverse burden under Section 123 of the Customs Act, 1962; Revenue must establish foreign origin and illicit importation through cogent evidence. Invoices identifying domestic consignors and consignees, interception away from the Indo-Myanmar border, and an inconclusive report suggesting possible North-East or Myanmar origin did not prove smuggling. Statements unsupported by independent evidence were insufficient to establish illegal importation. Consequently, confiscation of the betel nuts and related penalties were unsustainable.

Penalties under Section 112(b) of the Customs Act require admissible evidence of a person's involvement with confiscation-liable goods and proof that the person knew or had reason to believe the goods were liable to confiscation. Third-party statements cannot support liability unless the examination-in-chief requirement under Section 138B is met. An allegation that a person was an intended recipient of seized gold, without independent evidence of receipt, possession, control, transport, concealment, financing, or other dealing, does not establish the required knowledge. The penalties were therefore set aside.

Penalties imposed on Chartered Engineers cannot stand once the principal import proceedings and their associated demand, interest, confiscation and penalties have been invalidated. The alleged under-valuation lacked corroborative evidence, revaluation was arbitrary, and the proceedings were time-barred. With no enforceable underlying demand or related penal consequence, no independent basis remains for penal action against the Chartered Engineers; the penalties were therefore set aside.

IGST assessable value for goods imported under a duty-free import authorisation includes the value of imported goods and customs duty actually chargeable. Where an applicable exemption reduces basic customs duty to nil, the effective nil duty, rather than the tariff-rate duty, applies to the valuation computation. A nil duty debit under the authorisation confirms that no basic customs duty is chargeable. Electronic assessment cannot add tariff-rate basic customs duty notionally while disregarding the available exemption.

Customs seizure of a gold chain was challenged through special leave petitions seeking its release, alleging absence of a show-cause notice and breach of natural justice. The Supreme Court dismissed the petitions in view of its prior decision on the issue, which governed the request for release of the seized chain.

Protective addition of cash deposits as unexplained cash credit under Section 68 is unsustainable where the actual beneficiaries of accommodation entries are identified and no genuine uncertainty exists about the person assessable. A bank passbook or statement is not the assessee's books of account where no books are maintained, preventing invocation of Section 68 on that basis. Commission income may be estimated from the admitted entry arrangement at 0.3% of deposits. Enhancement to 0.5% without supporting evidence and a reasonable hearing under Section 251(2) is unsustainable; the original commission addition remains while the enhancement is deleted.

Revision under Section 263 is unavailable where a limited-scrutiny assessment was not converted to complete scrutiny under applicable instructions, because revision cannot enlarge the permissible scrutiny scope. The Principal Commissioner must independently examine the record and form the required opinion; an audit objection or Assessing Officer proposal cannot substitute that statutory exercise. Interest awarded under Section 28 of the Land Acquisition Act is characterised as accretion to enhanced compensation, taxable, if at all, under Section 45(5), rather than income from other sources. Where exempt agricultural land is involved and the Assessing Officer adopted a plausible view, neither error nor prejudice to Revenue is established for revision.

Section 54 exemption for capital gains requires unutilised gains to be deposited in the Capital Gains Account Scheme before the section 139(1) return-filing date. This deposit requirement is a mandatory statutory condition, and binding jurisdictional precedent requires strict compliance; contrary High Court decisions have only persuasive value. Capital gains neither utilised nor deposited in the prescribed scheme by the relevant filing date do not qualify for exemption, which remains limited to amounts utilised by that date.

Revision under section 263 requires both an erroneous assessment order and prejudice to Revenue; it cannot substitute a further enquiry where the Assessing Officer has made adequate enquiries and adopted a legally permissible view. For Ind-AS-compliant companies, the specific book-profit framework applies: mark-to-market loss arising from initial fair-value recognition of preference-share investments need not be added back where recognised through profit or loss. Unwinding interest on a contractually required, reliably estimated road-renewal provision represents accretion of an ascertained liability, not an unascertained liability requiring adjustment. The accepted book-profit computation consequently remains sustainable on jurisdiction and merits.

Best-judgment assessment followed repeated failures to respond to statutory notices or provide evidence supporting liabilities and expenditure, leaving only the audit report on record. Continued non-cooperation in first appellate proceedings did not justify deciding the substantial cash-credit additions and ad hoc expenditure disallowance on merits without a final evidentiary opportunity. The additions and disallowance require fresh determination after payment of costs, with a final opportunity to produce supporting material and no further unjustified default.

Absence of express irrevocability or dissolution clauses in a public charitable trust deed does not, by itself, justify refusing registration under Section 12AB or consequential approval under Section 80G. A public charitable trust is treated as irrevocable unless the trust instrument expressly permits revocation. Concerns over the transfer or application of net assets on dissolution are addressed through Section 115TD and cannot independently support denial. Where the trust's charitable activities and objects remain unchanged, registration under Section 12AB and approval under Section 80G should be granted.

Section 69C requires proof that expenditure was actually incurred before its source may be questioned; diary notings alone do not establish off-book spending without independent corroboration. Section 69A does not apply where a recorded cash balance arises from reversal of previously booked labour expenditure and corresponding recognition of income, rather than an undisclosed cash receipt. Interest on fixed deposits maintained as margin or security for bank guarantees connected with eligible infrastructure contracts may form part of profits qualifying for deduction under Section 80IA(4), where the deposits have a direct business nexus and are not investments of surplus funds.

Section 250(6) requires an appellate authority to identify the points for determination and give a reasoned decision on each ground. An ex parte order that merely confirms a reassessment because the assessee did not respond to notices, without deciding the grounds on merits or recording reasons, does not meet that requirement and is invalid. The appellate authority's powers are co-terminous with those of the Assessing Officer and permit further enquiry where necessary. Fresh adjudication after giving both sides an opportunity is required.

Pre-scheme self-assessment tax paid for the relevant assessment year must be credited against tax, surcharge and penalty under the Income Disclosure Scheme where it is demonstrably linked to the disclosed income, remains unadjusted against another liability, and is consistently reported in prescribed declaration and proof-of-payment forms. The Scheme contains no express bar on credit for such prepaid tax. Its recognition of credit for tax deducted at source supports comparable adjustment of directly relatable pre-scheme payments. Such payment is treated as Scheme payment, completing the required liability and entitling declarants to Form No. 4.

Income-tax notices under Section 143(2) may be issued by either the Assessing Officer or a duly prescribed income-tax authority. Centralisation of a case with a designated Assessing Officer does not, by itself, remove the prescribed authority's competence to issue such a notice. Notices under Section 142(1) are information-gathering measures that do not finally determine liability or prejudice rights. Jurisdictional and factual objections may be raised during assessment and through statutory appeals; writ jurisdiction generally does not intervene at this preliminary show-cause stage while effective remedies remain available.

Provisional attachment and lien over fixed-deposit receipts are to be lifted once security equal to 25% of the aggregate outstanding and anticipated tax demand is furnished through a post-dated cheque. This level of security exceeds the CBDT benchmark of 20% payment for stay of demand and adequately protects Revenue interests. Release remains conditional on an undertaking not to transfer the assets or create third-party rights in them.

Reassessment beyond three years requires books of account, documents or evidence showing income escapement; an audit objection alone, particularly one reappraising material examined in scrutiny, cannot satisfy this condition or permit review through a change of opinion. Writ jurisdiction remains available for a jurisdictional challenge to a reassessment notice despite an alternative appellate remedy or consequential assessment order. Excise-duty refunds received under an industrial incentive scheme for establishing an undertaking are capital receipts rather than taxable revenue income. Goodwill arising on amalgamation qualifies as a depreciable intangible asset, and an audit-based contrary view without new material cannot support reopening of an earlier allowance.