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.

Interest paid to government-owned corporations or government departments was exempt from tax deduction at source under the exemption for corporations established by Central, State or Provincial legislation. Notification No. 3489 applied without requiring a separate notification for each payee. The relevant payees were wholly government-owned corporations or government departments, and the same treatment had been accepted in other assessment years. Consequently, no liability for failure to deduct tax or consequential interest arose, and the demand was deleted.

Interest expenditure on borrowings used to advance funds on interest is deductible where banking records and confirmed accounts establish a direct nexus between the borrowings, onward advances and corresponding interest transactions. Consistent allowance of the deduction in preceding and succeeding assessment years, including a scrutiny assessment, supports application of the principle of consistency. On these facts, interest paid on the borrowings qualifies for deduction under Section 57 of the Income-tax Act, 1961.

Section 80P(2)(a)(i) allows a co-operative society to deduct the whole of profits and gains attributable to banking business or providing credit facilities to its members. A co-operative society providing member credit facilities under parent-body and NABARD guidelines remains eligible where it does not undertake banking business within the Banking Regulation Act definition. Providing credit facilities alone does not make such a society a co-operative bank, so the statutory deduction applies to qualifying profits from member credit facilities.

Unrecovered advances arising from construction and real-estate operations are allowable as a general business deduction under Section 37(1) when they become irrecoverable in the ordinary course of business. Failure to satisfy the condition under Section 36(2) for a bad-debt deduction does not preclude relief where the write-off represents a genuine loss incurred during normal business activity. The unrecovered advances are therefore deductible as a business loss under the general provision.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where scrutiny addresses cash deposits, the taxpayer supplies cash-flow details, and the Assessing Officer treats deposits as business turnover while estimating income, a legally permissible and factually plausible view is not rendered erroneous merely because the revisional authority prefers another view or seeks further verification. The principle confines revision to demonstrable assessment error causing prejudice, rather than substitution of the revisional authority's judgment.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. In limited scrutiny, the Assessing Officer had sought and received expense particulars, ledger extracts, vouchers and non-resident remittance details before accepting the returned income. No lack of enquiry or legal error was established. Further verification, or verification by a different method, cannot justify revision where the Assessing Officer has taken a plausible view; such action amounts to an impermissible fishing or roving enquiry. The revision was therefore unsustainable and the original assessment was restored.

Revisionary jurisdiction under Section 263 requires reasoned, independent satisfaction that an assessment order is both erroneous and prejudicial to the interests of the Revenue. Mere issuance of a show-cause notice followed by directions for a fresh assessment does not establish these statutory conditions. Without independent findings concerning the interest rate on loans and omission of an income-tax refund from the balance sheet, the exercise amounted to a fishing and roving enquiry. The revisionary order was invalid, quashed, and the original assessment order restored.

Bank credits arising in a contract business, where the return showing contract receipts was rejected without sound reasons but the business explanation for deposits remained unsubstantiated, require income estimation rather than full taxation as unexplained money under special-rate provisions. Ten per cent of the bank credits is assessable as normal business income; the entire credits cannot be assessed as unexplained money.