Section 50C applies to transfers of tenancy rights in land or buildings because a capital asset may be held through any legally recognised mode, not only ownership. Differences between leasehold and tenancy interests may affect the nature or value of the transferred interest but do not, by themselves, remove the transfer from the stamp-valuation framework. Where the stamp-value adopted exceeds the claimed fair market value, section 50C(2) provides for examination of the statutory conditions for a valuation reference. The Assessing Officer must consider the taxpayer's claim and, where conditions are met, obtain a Departmental Valuation Officer's valuation before determining the full value of consideration after providing an opportunity of hearing.

Surviving limitation following treatment of an original reassessment notice as a preliminary-enquiry notice is confined to the unexpired time remaining on the original notice's terminal date. After applicable statutory exclusions, the preliminary order and fresh reassessment notice must be issued within that balance, subject to the minimum seven-day period where applicable. Supplying material again does not restart limitation where it was already provided and answered. A fresh notice issued after expiry is time-barred and cannot create reassessment jurisdiction; consequential proceedings fail.

Under the mercantile system, an accrued but unpaid obligation to share overflow profit with investors remains deductible where its nature and accrual are undisputed. Lack of funds at the close of the previous year does not by itself make the liability contingent. The obligation arose under the investor arrangement, had neither ceased nor failed to accrue, and was outside payment-based liabilities governed by section 43B. Its subsequent discharge further supported the conclusion that it was not contingent. Accordingly, disallowance of the accrued outstanding liability was unsustainable.

Unaccounted mobile-accessories turnover may be assessed only for its profit element where purchases and business expenditure are inherent but exact computation is unavailable; the profit addition was limited to 5%, subject to removing overlap. Separate additions for cash salaries and supplier payments were treated as duplicative once trading profit was estimated. Property-booking cash additions required purchaser-specific proof of actual payment; uncorroborated booking sheets, cancellations and lack of recipient confirmation did not establish investment. Cash at company premises was not attributable individually where accounted company cash and business realisations explained it. Physical stock was limited to 5% of the valuation difference after excluding book stock and duplicated sales profit.

Amended section 115UB deems non-business losses accumulated by an investment fund up to 31 March 2019 to be losses of unit holders holding units on that date. Unit holders may therefore carry forward their proportionate attributed share under the amended regime, rather than the fund retaining those losses. The disallowance of such carry-forward was set aside, subject to verification of the unit holder's factual entitlement and the losses attributed by the investment fund.

Section 41(1) applies only where the taxpayer obtains a benefit during the relevant year through remission or cessation of a trading liability previously allowed as a deduction. Age of a liability, absent creditor confirmation, lack of recovery action or expiry of limitation does not establish cessation where the liability remains acknowledged in the accounts; subsequent payment may confirm that it continued at year-end. Advance-tax interest for a company remains mandatory but must be calculated on tax due on returned income, subject to statutory adjustments and credit for tax deducted at source and advance tax, rather than on subsequently assessed income.

Provisional release of seized imported goods may require an enhanced bond based on assessable value, but a bank guarantee calculated on anticipated fine and penalty is premature before verification of the certificate of origin and completion of investigation. Security requirements should protect revenue without treating prospective liabilities as established; prior final assessment of comparable goods receiving SAFTA benefit may support recalibration. Cargo-handling rules prohibit rent or demurrage on goods seized, detained or confiscated by the proper officer. Provisional release may therefore be secured through an enhanced bond and reduced guarantee, while detained goods qualify for complete waiver of demurrage and related charges.

Customs show cause notices may be corrected or supplemented before adjudication where a corrigendum causes no prejudice and relates back to the original notice; proper-officer status is function-specific. Recovery proceedings for duty not levied or paid are distinct from refund proceedings and need not be preceded by a separate challenge to self-assessment. Under Rule 2(a), CKD electric two-wheeler kits may be classified as complete vehicles when, as presented, they possess the vehicle's essential character despite missing battery packs and chargers. A CKD exemption requiring all necessary components is unavailable where components are missing, and an unclaimed alternative exemption cannot later be invoked. Confiscation remains distinct from redemption fine, so its absence does not preclude confiscation or penalty.

Customs interest arising solely because ICEGATE technical glitches prevented timely reflection of duty payment may be refundable where duty was remitted on the Bill of Entry filing date. The Tribunal treated the continued system failure, acknowledged up to 27 July 2023, as defeating a denial based only on filing the Bill of Entry after the waiver order's specified date. It set aside the rejection of the interest refund and allowed consequential relief according to law.

Appellate directions affirmed by the Supreme Court bind the parties and cannot be indirectly challenged through appeals against consequential compliance orders. Orders that merely implement or reiterate directions for fresh consideration, preserve existing interim arrangements, and neither decide the merits nor create new findings affecting rights do not warrant appellate interference. The Tribunal dismissed the connected appeals because they sought to reopen a prior appellate determination that had attained finality.

Seized records recovered under an undisputed panchnama, corroborated by transaction-linked witness statements, can establish prohibited foreign-exchange dealings despite a retracted statement. Forensic examination, panch-witness examination, or recovery of foreign currency is unnecessary where the records' genuineness, ownership and recovery are undisputed and other material proves dealings in foreign currency and gold. A delayed witness retraction may be treated as an afterthought, and later record misplacement does not erase material previously considered. Contravention under FERA was sustained, but the penalty was reduced because the amount was unquantified and the original penalty was excessive in light of health circumstances.

Conditional release of provisionally attached properties can protect quantified proceeds of crime while reducing prejudice to other investors. Under the escrow-based sale arrangement, attached properties may be sold through a joint escrow account, with the entire sale consideration deposited until the quantified proceeds of crime plus an additional 50 per cent is secured. The secured amount is then placed in fixed deposit pending the trial's final outcome. Attachment is lifted proportionately as properties are sold and fully once the stipulated aggregate is deposited. The Enforcement Directorate may monitor sales and release property documents needed for completion.

Concessional excise duty for power-driven pumps primarily designed to handle water requires strict satisfaction of the exemption conditions. "Water", undefined in the tariff, is understood in common and commercial parlance as clean water, excluding sewage and drainage water. Sewage and drainage pumps were therefore ineligible where their design and manufacturing differed from water-handling pumps; differential duty with applicable interest remained payable. An unimplemented audit objection did not create res judicata, and distinct tax periods have separate causes of action. Penalty for wrongful availment was set aside because the circumstances did not establish grounds warranting its imposition.

Sales-return movement may be supported by a delivery challan when goods are transported back without issuing a tax invoice. The challan should contain identifying and transactional particulars, including party details, goods description, quantity, taxable value, place of supply for inter-State movement, and signature. Tax rate and tax amount are required only where transportation is for supply to the consignee; they are not required for a sales-return movement. The e-way bill should classify the transaction as inward sales return and refer to the delivery challan where applicable.

Supervisory jurisdiction under Article 227 may remain available despite an appeal against an interlocutory injunction where the challenge is confined to the trial court's foundational lack of jurisdiction, rather than disputed facts or injunctive merits. After a liquidation order, Section 33(5) of the Insolvency and Bankruptcy Code restricts suits or legal proceedings by or against a corporate debtor, subject to the liquidator's approved proceedings. Section 63 further excludes civil-court jurisdiction over matters assigned to NCLT or NCLAT. Where the statutory bar is apparent, Order VII Rule 11 may be applied suo motu; any interim injunction issued without jurisdiction is a nullity.

Territorial jurisdiction under Article 226(2) depends on material and integral facts forming the cause of action, assessed consistently with the cause-of-action principle under the Code of Civil Procedure. The issuing authority's location, issuance of a circular, or electronic rejection from Delhi does not alone create jurisdiction. Where no-objection certificates concern import activity and detained goods at Chennai or Kolkata, the operative facts and alleged consequences arise there rather than in Delhi. Delhi therefore lacks territorial jurisdiction over the writ challenge.

Cash-deposit additions as unexplained money require a reasonable opportunity for the taxpayer to substantiate an asserted business-sales source. Where assessment treated deposits as unexplained despite retail-trading receipts being asserted, and the record did not show an opportunity to furnish supporting material or pursue presumptive assessment, principles of natural justice precluded sustaining the additions. The additions were directed for fresh adjudication, allowing fresh documentary material on the source of the deposits in renewed assessment proceedings.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. A mismatch between professional fees recorded in the accounts and payments reported for tax deduction under Section 194J did not establish unexplained or out-of-books expenditure. The tax audit report was based on regular books, while the tax-deducted payments related to operational costs of engaging professionals in the consulting business; separately disclosed legal and professional charges covered audit and other professional fees. The jurisdictional requirements for revision were therefore not met, rendering the revisionary order unsustainable.

Revision under Section 263 requires an assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where scrutiny records show that the Assessing Officer sought and considered detailed information on sales, purchases, TCS, rebates, discounts and rent payments, revision cannot rest merely on a preference for further or different verification. A factually plausible view, not contrary to law, does not render the assessment erroneous. The assessment was therefore not subject to revision, and the original assessment remained restored.

Cash deposits made by an authorised fair-price-shop dealer during demonetisation were directly linked to public distribution system sales. Goods were purchased from the State Civil Supplies Corporation, sold to eligible customers, and the sale proceeds were deposited in the bank account for further purchases. The deposits therefore constituted business receipts rather than unexplained money. Taxable business income was to be estimated on a presumptive basis at 8% of the deposits, after reducing income already offered.