Turmeric Extract / Curcuma Elixir, sold for direct human consumption as a general wellness nutraceutical or dietary supplement, falls under Heading 2106 as a food preparation. Classification follows primary function, essential character, common parlance and consumer perception, rather than medicinal qualities of ingredients; products intended for general well-being without specific therapeutic claims or drug recognition are not medicaments. The water-based product was also outside Chapter 33 because it contained no extracted essential oil and was not aromatic or intended for perfumery, cosmetics or flavouring. GST applied at 18% until revision and 5% from 22 September 2025. MRP does not affect classification or rate unless a rate notification makes it conditional on a value threshold.

Section 260-A permits a High Court appeal only where a substantial question of law arises; it does not allow reappreciation of evidence or replacement of concurrent factual findings. Concurrent findings that road and infrastructure works qualified the assessee as a developer eligible for deduction under section 80-IA(4) were based on the record, with no perversity or erroneous legal test shown. Reliance on a previously confirmed Tribunal order and dismissal of a similar appeal for another assessment year did not create a substantial question of law. The Department's appeal was dismissed.

Additional evidence before the Tribunal may be filed under Rule 18(4) of the Income Tax Appellate Tribunal Rules, 1963 through a separate paper book supported by an application explaining the reasons. The High Court upheld admission of records retrieved after loss, damage or soiling, particularly because the Assessing Officer had incorrectly recorded that no material was produced. The Tribunal's findings on unexplained cash credits and trading liabilities were based on confirmations, transaction details, tax-deduction certificates, books of account and bank records. As reasoned factual findings disclosed no perversity, no substantial question of law arose and the Revenue's appeal was dismissed.

Article 24(2) of the India-Netherlands DTAA does not entitle an Indian permanent establishment of a Netherlands bank to domestic-company tax rates where it remains a foreign company; the section 90 Explanation treats a higher foreign-company rate as non-discriminatory. Article 7's separate-enterprise fiction requires consistent treatment: interest remitted by an Indian PE to its overseas head office or branches is taxable in India, requires withholding, and is disallowed if withholding fails; interest received from them is taxable PE business income. ATMs qualify as computers for depreciation based on functional utility. Accounting Standard 19 does not govern tax characterisation; vehicle hiring payments remain deductible revenue expenditure absent an intention to acquire ownership.

Revisionary jurisdiction applies where a reassessment accepts non-taxability of accumulated interest without necessary inquiry or application of governing provisions, rendering it erroneous and prejudicial to Revenue interests and permitting fresh determination. Premature conversion of zero-coupon debentures into equity shares of ascertainable value can constitute constructive receipt of accumulated interest even under cash-basis accounting. Claiming tax-deducted-at-source credit for that interest is inconsistent with denying the underlying income. The capital-gains exclusion for conversion does not exempt embedded interest from taxation; once taxed, the interest forms part of the shares' cost basis, preventing double taxation on sale.

Electronic evidence lacking valid certification, proven device control, seizure records, chain of custody, hash value or corroboration cannot support income-tax additions. Digital ledger entries representing dummy, contra, adjustment or opening balances, without proof of actual receipt, do not justify unexplained-credit additions; unauthenticated WhatsApp chats alone likewise cannot establish unexplained money. Routine leased-premises repairs and annual software upgrades are revenue expenditure, whereas multi-period licence costs require apportionment under accrual and matching principles. Post-search assessments for covered preceding years must follow the prescribed reassessment procedure; use of regular scrutiny assessment is jurisdictionally defective.

Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.

Section 80IA/80IB deductions were available to a new hydraulic power steering gear undertaking that operated as an integrated, independent manufacturing unit and commenced production before the statutory cut-off. Separate premises, new machinery, capital, workforce, power load, production, accounts, sales and excise records supported its independent character; subsequent machinery additions merely increased capacity. Initial-year eligibility continued through consecutive eligible years where no material facts changed. Depreciation was allowable for machinery installed and kept ready for business use, as passive use satisfies the business-use requirement where contrary evidence is absent. Deductions and depreciation were allowed for the relevant years.

Recording of satisfaction by the Assessing Officer during assessment is required before penalty proceedings under section 271D can be initiated for cash receipt of immovable-property sale consideration. Where jurisdictionally binding precedent requires this satisfaction, a contrary Tribunal view based on law binding in another jurisdiction does not govern. When High Court interpretations diverge, the interpretation favourable to the assessee applies. On that basis, deletion of the penalty was sustained, the Revenue's appeal was dismissed, and the assessee's cross-objection became infructuous.

Transitional reassessment notices must be issued within the surviving limitation available under the legal fiction, after prescribed exclusions. Where the new-regime notice is issued after that period, the resulting reassessment is void from inception, non est and incapable of revision because a valid subsisting assessment is a condition precedent for revision. Revision also requires both an erroneous assessment and prejudice to Revenue. Inquiry into exempt long-term capital gains supported by transaction records, contract notes, demat evidence, banking trail and securities transaction tax cannot be treated as erroneous merely because the inquiry was not extensively recorded or further inquiry is considered desirable.

Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.

Section 271(1)(c) treats concealment of income and furnishing inaccurate particulars as distinct penal defaults, requiring clear identification and proof of the specific charge. Mere non-disclosure does not establish inaccurate particulars unless the return contains incorrect or false details. An explanation offered during assessment, not found false and used to quantify the addition, may support bona fides and prevent application of Explanation 1. Although tax penalties do not require proof of mens rea, an addition alone does not make penalty automatic. On these facts, the absence of a specific default and failure to satisfy Explanation 1 led to deletion of the penalty.

Direct appeals to the Tribunal against an Assessing Officer's rectification order under section 154 are not maintainable where the statutory appeal to the Commissioner (Appeals) has not first been filed. The prescribed appellate sequence requires the aggrieved taxpayer to pursue the first appellate remedy before approaching the Tribunal. An erroneous reference in Form No. 36 to a Commissioner (Appeals) order does not convert the proceeding into a valid appeal against that order.

Capital grants, subsidies and consumer contributions reduce the actual cost or written-down value of relevant assets for depreciation. Where not directly attributable to a particular asset, they require allocation among the affected assets at their respective depreciation rates. Book-profit adjustments for such grants, including subsidy grants received in advance, require an identified clause in the Explanation to section 115JB(2); treatment under normal tax provisions alone is insufficient. Borrowing-cost capitalisation depends on direct attribution to qualifying capital projects and cannot rest on an unsupported assumed historical rate or unsubstantiated accounting-method change. Assistance for beneficiary-owned solar systems is revenue i.....

Provisional release of seized Ketamine Hydrochloride for export was warranted where a fresh export authorisation covered the same goods after the original authorisation had expired following replacement of the shipment batch. The High Court treated the delay in obtaining the fresh authorisation as technical because the goods remained unexported and the licensing authority had accepted the new authorisation as valid. Customs could not deny its effect merely because the licensing authority had not expressly authorised release of the seized goods. Union departments must maintain consistent positions on the same export transaction. The rejection of provisional release was quashed, subject to a Customs deposit, while adjudication and criminal proceedings remained unaffected.

Capital goods intended for use in a warehouse authorised to undertake manufacture or other operations may remain warehoused until clearance under the amended customs framework. Interest on warehoused goods is confined to residuary goods and does not apply to capital goods falling within the specified category. Intended use is determined when the goods are imported and warehoused; actual subsequent use is not required. Solar modules intended for a solar power project retained their character as capital goods despite becoming surplus because of later design and layout changes. A circular concerning clearance for non-manufacturing purposes cannot impose interest where the statute does not provide for it.

Royalty and licence fees may be included in the customs transaction value only where Revenue establishes a direct and proximate relationship with the imported goods and proves that payment is a condition of their sale. The explanation concerning post-import processing does not independently expand these requirements. Royalties payable for technology transfer, intellectual property, or post-import manufacturing rights are not linked to imports merely through a broad commercial connection. Where royalty arises from manufacture and sale of finished products, is neither conditional on component imports nor calculated by their value or quantity, it is not includible in the assessable value of imported components.

Self-assessed bills of entry constitute appealable assessment orders, even without departmental reassessment, a lis or a speaking order. Waiving notice and personal hearing for expedited adjudication does not, absent an informed and express surrender, waive the independent statutory right to challenge tariff classification. In reclassifying Rivet Mobile Contact, Revenue bears the burden of proof; evidence of silver content alone does not resolve classification where dedicated design and use establish its essential character as an electrical contact. The product is excluded from Chapter 71 and classifiable under CTH 8538. Without misdeclaration of description, quantity or value, a bona fide classification dispute alone does not support confiscation, redemption fine or penalty.

Actual-user compliance under an end-use customs exemption is met where imported wind-operated electricity generator parts are used exclusively to erect and commission windmills in the specified turnkey project. The condition requires ultimate use for the prescribed purpose but does not expressly bar movement of components to the project site or transfer of title under supply contracts before final assembly. Continuous ownership by the importer until commissioning is not required where the importer remains responsible for installation and commissioning. Contractual transfer before final assembly therefore does not, by itself, breach the concessional exemption condition.

Medical-device parts and accessories suitable solely or principally for use with a Cell Separator are classifiable with that device under Chapter 90. The residual tariff entry for parts and accessories applies only where the goods are not otherwise specified or included within that Chapter. AMICUS Platelet Kits and similar Cell Separator accessories therefore fall under CTH 9018 rather than the residual CTH 9033 classification. This classification attracts IGST at the rate prescribed for medical devices and related goods under the relevant Schedule entry.