GST-return mismatch alone does not establish undisclosed business turnover where no evidence identifies off-book sales, unaccounted purchases, receipts or bank transactions. Reconciliation through sales ledgers, monthly GST returns and annual GSTR-9 may demonstrate that differences arose from duplicate reporting, including turnover repeated in a later GSTR-1. Verifiable statutory records produced after an ex parte assessment remain relevant and cannot be rejected merely because they were not earlier furnished. Without proof of actual undisclosed turnover, an estimated gross-profit addition on differential turnover cannot be sustained.

Reasonable cause under section 273B excused initial non-compliance with notices issued under section 142(1) during reassessment proceedings. The assessee's explanation that counsel's assistant was unavailable was considered plausible because the assessee subsequently participated, furnished the required replies, and enabled completion of reassessment under section 143(3) read with section 147 rather than by best judgment assessment. The ITAT therefore treated the subsequent conduct as supporting reasonable cause and deleted the penalties imposed for failure to comply with the notices for both assessment years.

Section 144C(13) imposes a mandatory one-month limit, running from the end of the month in which Dispute Resolution Panel directions are received, for completion of the final assessment. This special timeline overrides general assessment limitation provisions. Electronic upload of directions on the ITBA portal constitutes valid communication under the electronic assessment regime. Accordingly, directions uploaded and received in August 2024 required completion of the final assessment by 30 September 2024; an assessment completed later is time-barred, leaving merits issues academic.

Compensatory allotment of immovable property in substitution for previously acquired land requires factual verification before treating the difference between property value and declared consideration as deemed income under section 56(2)(x). If the allotment relates to an earlier acquisition rather than a fresh purchase, section 56(2)(x) may not apply. The assessment was remitted for verification and fresh determination of taxability. Penalty for under-reporting based on the unverified deemed addition was deleted as premature, while permitting fresh penalty proceedings if under-reporting is established on reassessment.

Managing director's performance-linked commission qualified for deduction under section 36(1)(ii) where it was board-approved remuneration for services, included in salary income and subject to tax deduction. The commission was not a dividend distribution because dividends had separately been declared. Its increase corresponded with turnover and profitability, and comparable commission had been accepted in earlier years. Applying consistency, uniformity and certainty in the absence of distinguishing facts, the disallowance was deleted and the appeal allowed.

Income from house property is chargeable to the owner, while a tenant that merely sub-lets leased premises is not treated as a deemed owner. Where leased commercial premises are systematically exploited through sub-letting coupled with maintenance, security, cleaning and related facilities, the receipts arise from commercial exploitation of leasehold rights rather than property ownership. Their character depends on the nature of that activity, not on the taxpayer's separate salary income. Such receipts are assessable as profits and gains of business or profession and should be computed under that head.

Penalty under section 271(1)(c) is not leviable on an alleged bogus-purchase addition that survives only as an ad hoc or estimated disallowance. The disallowance was restricted in appeal to an estimated percentage of the purchases. Following the coordinate-bench approach on estimated additions, the penalty was deleted and the assessee's appeal was allowed. An estimated disallowance for alleged bogus purchases, by itself, did not sustain the imposed penalty.

DFIA classification of liquid glucose concentrate under SION Entry E22 depends on the immediate manufacturing input: starch slurry qualifies as starch, and its origin from maize does not require classification under the maize-based Entry E76. Valid and subsisting DFIA authorisations obtained without wilful misstatement or suppression preclude recovery under Section 28AAA and related confiscation or penalties. The DFIA benefit therefore remains available for liquid glucose concentrate classified under Entry E22.

Customs Broker licence restrictions prohibit sale or transfer, but handling specified import transactions or obtaining business through a clearing and forwarding agent does not by itself establish either prohibited conduct or unauthorised Customs business. Special Import Licence debit entries are made, recorded and verified by Customs officers before out-of-charge; where the licence is valid and not alleged to be forged, a Customs Broker who only submits it is not responsible for debit discrepancies. A material reduction between the over-debiting alleged in the show-cause notice and the limited debit ultimately attributed, together with the Broker's limited role, made the revocation order unsustainable. Licence revocation, security forfeiture and penalty were set aside.

Export transaction value remains the price paid or payable by the buyer for delivery at the place of export where otherwise acceptable. Overseas agency commission paid from sale proceeds is a selling expense: Customs valuation rules neither require its deduction nor impose a ceiling, including where it exceeds 12.5% of FOB value. For Duty Drawback, RoDTEP and RoSCTL, agency commission and foreign bank charges are deductible from FOB value only to the extent exceeding 12.5% for incentive computation, subject to correct shipping-bill declaration. Remittance permissibility under FEMA, RBI directions and foreign trade law remains outside this scope.

Participation in arbitration despite knowledge that a sole arbitrator departs from an agreed three-member tribunal, coupled with consent to time extensions and counterclaims, constitutes waiver and acquiescence in the tribunal's composition. An insolvency moratorium restricts recovery proceedings against a corporate debtor but does not bar it from pursuing its own arbitral claims, including through persons authorised by the resolution professional with creditor-committee approval. Extension of an arbitral mandate lies with the court defined as the principal civil court of original jurisdiction or an original-jurisdiction High Court. Appointment jurisdiction for constituting a tribunal creates no continuing supervisory power to extend its mandate and does not trigger exclusive-jurisdiction rules.

Investor compensation claims arising from a fraudulent prospectus may, where the issuer is in insolvency and fraudulent-trading proceedings are pending, be treated as proceedings benefiting all creditors rather than personal claims. Recovery from allegedly responsible persons, including the statutory auditor, must be pursued within the insolvency framework for the Committee of Creditors. A civil suit against the auditor was therefore rejected, with recourse identified under the IBC fraudulent-trading provision. Allocation of fraudulent-trading recoveries to a resolution applicant reflects the Committee of Creditors' commercial bargain and does not create a general exclusion of creditors.

Committee of Creditors may, through commercial wisdom, invite fresh expressions of interest by publishing a Third Form G where a remitted resolution plan and settlement proposal fail to secure statutory approval. Approval of an earlier plan does not give the resolution applicant an indefeasible right before approval under Section 31; absent legal infirmity, the decision need not be judicially substituted. Assigned creditor claims recognised only after committee voting do not retrospectively alter the voting position where original allottees remained creditors of record, and unproved allegations of fraud or material irregularity do not invalidate prior decisions. Intervention cannot introduce independent issues beyond the appeal's subject matter. Publication was upheld, while the challenges and intervention applications failed.

Section 60(5) jurisdiction extends to a Liquidator's recovery of unpaid business-purchase consideration where the amount is a receivable of the liquidation estate and its recovery directly augments assets available to creditors. A contractual provision envisaging payment from income generated by the acquired business governs the payment mechanism but does not extinguish the purchaser's primary payment obligation. Controlling directors who acquired and exercised effective managerial, financial and operational control through the purchaser-company cannot rely on privity or separate corporate personality to avoid liability arising from their own acts. Recovery, with interest, was confined to the purchaser-company and the three controlling directors against whom relief was sought.

Section 19 of the Prevention of Money-Laundering Act permits arrest only where the authorised officer records reasons to believe, based on material, that the person is guilty, and compliance is subject to judicial review. After the enforcement authority used section 50 summons powers to examine a cooperating person on existing material and obtained no fresh incriminating material, it could not resort to arrest on that same material without a supervening circumstance making arrest imperative. The High Court treated such recourse as a colourable exercise of power, held the arrest non-compliant with section 19, quashed the remand orders, and directed immediate release.

Supply of relied-upon documents in PMLA complaint proceedings engages the trial court's fair-trial obligation to provide complaint materials to the accused. Whether the best available copies were furnished or documents are unavailable remains for determination on the trial-court record; inherent jurisdiction should not pre-empt that factual determination absent patent illegality or lack of jurisdiction. Observations made to secure compliance with document-supply timelines do not determine the integrity of the investigating agency or officer and should not affect other proceedings. Investigating Officer attendance may be required when necessary, including through video-conferencing, but not automatically on every hearing date; each direction should specify its purpose.

Under PMLA, the discretionary and drastic arrest power requires observance of statutory safeguards. Where the investigating authority obtains permission to examine an accused on existing material but abandons that examination, arrest on the same material requires strong fresh incriminating material or supervening circumstances warranting immediate action. Omission of the earlier examination order from the arrest application, coupled with failure to address the objection at remand, supports judicial review and may indicate a colourable exercise of power. On the stated facts, the arrest was treated as unsustainable; remand orders were set aside and bail granted subject to conditions, without affecting trial merits.

Unsubstantiated advertising receipts retained after identifiable advertising expenditure, where no agreement or supporting material establishes the claimed commission, may be treated as proceeds of crime in the recipient's possession when the statutory burden is not discharged. Property of equivalent value may be provisionally attached where directly or indirectly derived criminal property is unavailable because it has vanished or been laundered. Immovable property so attached represents the value of unavailable proceeds, rather than direct proceeds of crime.

VCES eligibility is assessed as at the prescribed date; an investigation initiated later does not retrospectively disqualify a declarant. A higher tax computation based on contracts, accounts, returns and tax records does not, without identified material discrepancies, establish a substantially false declaration where receipts raise disputes over taxability, classification, valuation or taxes paid by principal contractors. The statutory deeming rule invokes recovery machinery but does not alter the return-based relevant date or restart limitation. Extended recovery requires deliberate suppression with intent to evade; reconstruction from disclosed records and legal characterisation disputes does not meet that standard. VCES payments remain non-refundable under the statutory bar.

Admitted execution and delivery of settlement cheques trigger presumptions of consideration and legally enforceable debt; a security-cheque defence must provide a probable basis to displace them. Completion of particulars in a voluntarily delivered signed cheque differs from material alteration, which requires proof of an unauthorised change to an existing entry; a collecting-bank endorsement alone does not establish alteration. Additional defence evidence on appeal is not an unrestricted entitlement and may be refused when belated, unproved, or unnecessary. Compensation should realistically reflect the cheque amount and deprivation of payment. The conviction, compensation and default sentence remained, while substantive imprisonment was reduced to six months based on individual circumstances and deposits.