Section 62 of the Insolvency and Bankruptcy Code imposes a 45-day appeal period and permits condonation for no more than 15 additional days; its self-contained limitation regime prevails over Companies Act appellate provisions. "Date of receipt" does not allow a litigant to postpone limitation by delaying an application for, or collection of, a certified copy. Pronouncement in open court constitutes pronouncement of the order, and Section 12(2) of the Limitation Act excludes only the period from applying for the copy until it becomes available, not preceding inaction. Because the appeal exceeded the absolute 60-day ceiling even after permissible exclusion, it was time-barred and delay could not be condoned.

Finality of prior appellate directions affirmed by the Supreme Court prevents renewed appellate interference with consequential implementation orders. Where an impugned order merely reiterates binding directions and contains no independent factual or legal finding on the merits of the company petition, a challenge to that order would indirectly reopen matters already settled. Connected compliance directions remain governed by the finality of the affirmed appellate directions.

Rule 22 of the Customs, Excise and Service Tax Appellate Tribunal (Procedure) Rules, 1982 was applied after the appellant's death certificate was produced. The customs appeal consequently abated. The operative point is that the appellant's death, established through the submitted certificate, brought the pending appeal to an end under the Tribunal's procedural framework.

Section 123 of the Customs Act places the statutory burden of proof on the relevant party only for notified goods. As the seized betel nuts were neither prohibited nor notified goods, the Revenue bore the burden of establishing that they were smuggled. That burden was not discharged on materially identical facts arising from the same adjudication order. The penalty was therefore unsustainable because smuggling of the seized goods remained unproved.

Interest on customs duty may be waived where payment for a bill of entry was initiated on time but remained uncredited because of continuing ICEGATE technical failure. Although the Customs (Waiver of Interest) Third Order limited relief to bills of entry filed by a specified cut-off date, continuing system disruption acknowledged in a later advisory and bank evidence of timely payment initiation supported waiver and refund despite that cut-off. Technical failures causing delay in crediting payments may therefore protect importers from interest liability where timely payment initiation is established.

Customs duty recovery under Section 28 may proceed notwithstanding self-assessment, because recovery of unpaid duty is distinct from refund proceedings; differential duty was therefore recoverable. CKD e-bike components with pre-assembled essential parts may be classified under Rule 2(a) as complete electrically operated motorcycles despite absent batteries or chargers. Concessional exemption for a knocked-down kit requires all components necessary for assembly, and an alternative exemption not claimed in Bills of Entry cannot later be invoked; both benefits were unavailable. A pre-adjudication corrigendum correcting the answerable authority caused no prejudice, while pre-notice consultation had occurred, preserving notice validity. Confiscation and penalty remained sustainable even without redemption fine.

Provisional-release security should protect the assessable value through a bond without requiring security for fines or penalties that remain unascertained pending investigation and consequential proceedings. Security conditions may be recalibrated where prior clearance of goods from the same exporter on a certificate of origin is relevant. Regulation 6(1)(l) bars a Customs Cargo Service Provider from charging rent or demurrage on seized, detained or confiscated goods, subject to other applicable law. The detained consignment consequently received complete waiver of demurrage and related charges.

Sufficient cause under limitation law requires a credible, bona fide explanation, particularly where delay is inordinate; condonation cannot be granted mechanically despite negligence, inaction, or lack of diligence. Receipt of the order by counsel, a vague explanation for prolonged delay, and the litigant's failure to pursue the proceeding while continuing business activity showed insufficient vigilance. A litigant must monitor its litigation and cannot attribute the entire delay to counsel. On those facts, refusal to condone the customs appeal delay was justified, and no substantial question of law arose.

Classification disputes concerning imported goods fall outside High Court appellate jurisdiction where they require determination of the applicable customs duty rate. Section 130 excludes appeals involving questions on the rate of duty or value of goods for assessment, while Section 130E directs appeals from Appellate Tribunal orders determining those questions to the Supreme Court. Consequently, an appeal concerning classification and resulting duty liability must be pursued before the Supreme Court, not the High Court.

Royalty payments for trademark and marketing know-how must be benchmarked separately from branded-product purchases under the Resale Price Method, which tests gross margins and does not absorb royalty incurred below the gross-profit level. A Comparable Uncontrolled Price adjustment cannot rely on unsigned, unexecuted franchise-agreement templates rather than actual uncontrolled transactions; the royalty adjustment was deleted. Restricted stock-unit costs, shared IT support charges, and recurring tester, advertising, and sales-promotion expenditure qualified as business expenditure under Section 37(1), resulting in deletion of the related disallowances. Set-off of brought-forward business losses and unabsorbed depreciation requires verification and allowance in accordance with law.

Section 153A permits disturbance of completed or unabated assessments only where incriminating material found during the assessee's search reveals undisclosed income and directly relates to the proposed addition. Unsecured loans already disclosed in the books cannot be added merely from assessment-stage inquiries, subsequent third-party material, lender verification, or an alleged failure to establish creditworthiness. Search statements must specifically indicate fictitious loans, cash exchange, or unaccounted funds; their absence cannot support additions. Corresponding interest disallowances likewise lack foundation where no year-specific incriminating material exists. The loan-transaction merits remain unexamined under this jurisdictional limitation.

Articles 7 and 24 of the India-UAR DTAA treat the Cairo place of management as a permanent establishment, permit taxation of attributable business profits in the UAR, and require exemption of that income in India while allowing rate inclusion. Indirect expenditure relating to exempt income is determined under the accepted allocation methodology after considering expenditure already disallowed. Book-profit computation includes income tax paid or payable but does not extend to wealth-tax provisions. Reversal of a provision for diminution in investment value does not require a further book-profit adjustment where the provision was added back when created and its earlier treatment did not affect taxable income.

Section 41(1) applies only where a prior allowance or deduction exists and the taxpayer obtains a benefit through actual remission or cessation of a trading liability during the relevant year. Outstanding trade-creditor balances that remain acknowledged in the accounts do not become taxable solely because they are old, unconfirmed, unrecovered, or time-barred; waiver, settlement, write-back, discharge, or another event evidencing cessation or benefit is required. Interest for deferment of advance tax under section 234C is mandatory but, for a company, must be computed on tax due on returned income after statutory adjustments and credits, rather than on assessed income merely because the assessment income is higher.

Article 12(4)(b) of the India-Singapore tax treaty treats technical, managerial or consultancy services as fees for technical services only where they make available technical knowledge, experience, skill, know-how or processes for independent use by the recipient. Recurring software maintenance, remote support, bug resolution, standard updates and user training do not meet that condition where customers remain dependent on the service provider. Software migration from an old version to a new version likewise does not qualify without transfer of independent technical capability. Such receipts are business receipts and are not taxable in India absent a permanent establishment.

Section 115UB(2A) deems eligible non-business losses accumulated by an investment fund as on 31 March 2019 to be losses of unit holders holding units on that date. A unit holder may carry forward the attributable loss for the remaining statutory period and set it off under Chapter VI. Attribution must be made on a pro-rata basis through the fund's statement, with verification that the loss was attributed to the unit holder and was not available to the fund after 1 April 2019.

Identified unrecorded sales constitute business turnover, not unexplained money taxable in full; taxability is confined to a 5% profit estimate after removing duplicated sales. Cash salaries and supplier payments connected with the same unrecorded trading activity are subsumed in that estimate and cannot be separately added without a distinct source or expenditure, avoiding double addition. Alleged cash investment requires reliable evidence identifying the payer, payment and relevant year; common workbook entries and statutory presumptions alone are insufficient. Accounted cash and explained trading realisations are not unexplained money. For stock, only the physical-to-book valuation difference is considered, with overlap eliminated.

Under the mercantile system, an accrued liability for investors' share of profit is deductible where its existence and accrual under the relevant arrangement are undisputed. Section 43B's payment-basis restriction applies only to specified liabilities and does not extend to this profit-sharing obligation. Outstanding non-payment or lack of funds does not render the liability contingent unless evidence shows that it never accrued or has ceased. Subsequent payment supports the liability's continuing existence; the related disallowance is therefore not sustainable.

Statutory assessment limitation may be extended on the basis of a foreign-tax reference only where evidence of the reference substantiates the extension; an unsupported assertion leaves assessments time-barred and void from inception. In search assessments for unabated years, expenditure recorded in regular books cannot be disallowed without seized incriminating material. Agreements, invoices, banking records and confirmations can establish the genuineness of excavation expenses and professional charges included in work-in-progress and discharge the taxpayer's burden of proof. On those principles, the expense additions were unsustainable and the assessment orders could not stand.

Recorded cash balance may explain bank deposits made during demonetisation where the cash in hand immediately before demonetisation exceeds the deposits and the cash book, bank entries and stock records contain no identified discrepancy. Section 68 permits scrutiny of the nature and source of credits, and the human-probabilities test allows examination beyond book entries, but neither justifies disregarding recorded cash solely through an estimated cash-sales ratio. Where no fictitious sale, unexplained deposit or defect in cash-flow records is identified, and the ratio is not an independent historical benchmark, the recorded balance adequately explains the deposits. The addition for alleged inflated cash sales was deleted.

Failure to attend the hearing, seek an adjournment, or provide written submissions and supporting material may justify dismissal of an appeal for non-prosecution where adequate and reasonable opportunity has been given. Appellate tribunals possess inherent power to dismiss proceedings when an appellant neither appears nor pursues the matter, as continuing such proceedings serves no purpose. The appeal was dismissed for non-prosecution, while preserving liberty to seek recall by substantiating reasons for non-compliance with the hearing notice.