Assessment limitation following remand of a transfer-pricing issue is governed by section 153(3) where the remand is to the Assessing Officer under Rule 28 and requires verification and a hearing. A fresh reference to the Transfer Pricing Officer, absent fresh satisfaction under section 92CA(1), does not attract section 153(4) or extend the completion period; the consequential assessment was therefore quashed as time-barred. Although quoting a DIN in Dispute Resolution Panel directions is mandatory, omission from the directions did not invalidate them where a separate authenticated intimation identified the directions and carried the DIN. The DIN objection was rejected.

Compulsory-acquisition compensation for agricultural land in the Hazira Notified Area was not chargeable to capital-gains tax because the land lay outside a municipal area, retained its agricultural character, and was used for agricultural operations. The resulting capital-gains addition on land compensation did not survive. For compensation attributable to built-up structures and other assets acquired with the land, 60 per cent of the relevant compensation was allowable as cost of acquisition when computing consequential capital gains.

Interim judicial restraint preventing treatment of foreign-leg Leave Fare Concession reimbursements as income for tax-deduction purposes meant the deductor did not breach an enforceable deduction obligation; tax-default demands and consequential interest were therefore deleted. Subsequent substantive taxability could not retrospectively turn compliance with the subsisting direction into a default. Compliance with that direction also constituted statutory reasonable cause, supporting deletion of non-deduction penalties. Institutional delays in penalty appeals were condoned where multi-level approvals, lost portal access after personnel changes, and access resetting showed sufficient cause without deliberate delay, mala fides, benefit to the deductor, or prejudice to revenue.

Benami characterisation of land acquired in an apparent purchaser's name rested on cumulative evidence of limited financial means, a statement that the sale deed was signed at the beneficial owner's behest, documented nexus between them, and proof of the payment source. A later retraction affidavit lacked support and was treated as unreliable because it conflicted with the sale deed, was delayed without explanation, and referred to an implausible future event. The land was treated as benami property, sustaining confirmation of provisional attachment.

Interest on IGST levied on imported goods cannot be recovered where neither the Customs Tariff Act, 1975 nor the Customs Act, 1962 contains a charging provision authorising such interest. The issue was treated as settled by earlier precedent, rendering the interest collection unsustainable. Refund claims for interest paid must be considered expeditiously and within 16 weeks of receipt, provided the claimant establishes that the interest burden was not passed on to buyers or customers.

Section 129DD permits the revisional authority to annul or modify an appellate customs order and, absent an express prohibition, remit confiscation and redemption proceedings for fresh adjudication. Revisional review may correct an appellate finding that overlooks material evidence, including circumstances relevant to a purchase invoice and the claimant's burden to prove lawful import, without finally deciding redemption or confiscation. A separate show-cause notice is required only for enhancement of penalty or fine or confiscation of goods of greater value; it is unnecessary for remand where the affected party has been heard. Statutory revision time limits cannot be enlarged under the Limitation Act, but a limitation challenge fails where the communication date is unproved. The writ petition was dismissed and remand sustained.

RBD Palmolein described in contemporaneous shipping and vessel records was classified as palm oil other than crude palm oil, so the concession available only to crude palm oil was denied. Reliable electronic correspondence and third-party shipping records, supported by other material and disclosed to the importer, were admissible in customs adjudication despite certification defects. Material misdeclaration sustained extended recovery and confiscation. The applicable duty rate required limited verification and recomputation, with statutory interest following. Redemption fine was reduced as disproportionate, and the misdeclaration penalty was limited to recomputed differential duty. A separate penalty for false documents was deleted because no distinct knowingly false document beyond the import declaration was identified.

Unchallenged order-in-original conditions requiring payment of customs duty, redemption fine and penalty for release of detained gold jewellery cannot be assailed indirectly after the available remedies against that order were not pursued. Earlier writ proceedings directing release in accordance with the order do not determine its validity. Recovery of customs duty as a condition of redemption therefore remains enforceable. Detention charges recovered on release may be challenged only upon establishing that their recovery contravened statutory provisions; no such statutory infirmity was shown.

Classification of imported stainless-steel melting scrap requires consignment-specific, reliable evidence; test reports for later consignments cannot displace a separately finalised assessment. Pre-shipment inspection and Chartered Engineer reports identifying goods as scrap remain material where chemical or laboratory evidence is inadequate, and buyer statements not tested under the prescribed evidentiary procedure cannot establish prime material. Uniform dimensions or orderly stacking do not alone establish prime material, while revaluation requires support for additional consideration. Goods cleared without bond or undertaking and unavailable for confiscation cannot be absolutely confiscated. Director penalties require a specific basis f.....

Refund of duplicated customs-duty payment may not be denied merely because an ICEGATE challan was not generated for the first payment. Where the importer provides the banking and payment records required by the Public Notice, verification through PAO/e-PAO and ICEGATE falls to the proper officer; an unavailable challan resulting from departmental system failure cannot be imposed as a refund condition. Refunds processed under the procedure for customs-duty refunds attract statutory interest where payment is not made within the prescribed period, at the rate notified by the Government.

Secured creditors must clearly and timely elect to realise a security interest outside the liquidation estate; merely recording a security interest in Form D does not communicate that election. An email sent after a compromise scheme fails cannot retrospectively cure non-compliance with Regulation 21A. Participation and voting in the Stakeholders' Consultation Committee are relevant, while consideration of a scheme under the Companies Act neither suspends nor extends the election period. Consequently, without a valid timely election, hypothecated assets remain in the liquidation estate and cannot be realised independently.

Corporate veil lifting for real estate project resolution treated the developer and the land-owning special purpose company as a single economic entity, bringing the leasehold land within the restored resolution plan. Allottee claims arising from the same project were addressed through completion and delivery under that plan, leaving no independently due debt to support a separate insolvency process. A parallel CIRP over the project land would impose a moratorium and vest management in an insolvency professional, obstructing implementation of the restored plan. The Monitoring Committee responsible for plan implementation had standing as an aggrieved person, and binding Supreme Court precedent required consideration. Allottees' remedy lay in enforcing the restored plan.

Suspension of an insolvency professional's registration renders the professional ineligible to continue in any ongoing insolvency process, rather than only the assignment underlying disciplinary action. Regulation 13(7) requires intimation of the suspension to the relevant Committees of Creditors and the Adjudicating Authority, operating separately from the Committee's commercial power to replace an otherwise eligible resolution professional. Challenges concerning disclosure, valuation, statutory recourse and disciplinary procedure raised issues for final consideration but did not establish a prima facie case, balance of convenience or irreparable injury. Interim stay of the disciplinary suspension was therefore declined, without determining the main appeal's merits.

FEMA adjudication concerning under-invoiced imports remains independent of Customs valuation and duty proceedings, and statements recorded under the Customs Act may be considered. Seized electronic records carry a rebuttable presumption of truth where their integrity is established; unrebutted records and related statements can prove foreign-exchange contraventions on a preponderance-of-probabilities standard. Contraventions may be sustained for documented import entries, but projections or extrapolations from electronic data require corroborative evidence and cannot alone support allegations. A person in charge of a company is personally liable for established corporate contraventions to the same evidence-based extent.

Specific nil-rate exemption entries for namkeen and similar edible preparations apply to Cheese Balls and Bhujia cleared in sealed retail pouches. Cheese Balls fall within the specific entry for similar ready-to-consume edible preparations, while the residual packaged-food entry applies only where no specific description covers the goods; sealed packaging does not displace the specific exemption. Bhujia is expressly covered by a separate specific entry, and its sealed-container restriction cannot be imported from a differently worded residual entry. Classification under Tariff Item 2106 90 99 remains within sub-heading 2106 90, so it does not exclude eligibility where the exemption refers to that sub-heading. Nil-rate treatment consequently applies and related duty, interest and penalties are unsustainable.

Disciplinary proceedings for other misconduct may continue after a complaint has been filed and are not rendered withdrawable by a later request to withdraw it. Pending disciplinary matters are governed by the pre-amendment legal framework where applicable. Constitutional writ review of disciplinary action remains limited, restricting judicial interference with findings or punishment except within the permitted scope of review. Removal from the Register of Members may be imposed as a disciplinary sanction for established misconduct.

Clubbing of clearances, lifting of the corporate veil, pervasive financial and management control, SSI-exemption aggregation, suppression of material facts, and the extended limitation period were the legal issues identified. The Supreme Court dismissed the appeals for want of any ground to interfere with the Tribunal's impugned order, leaving that order undisturbed on all listed issues.

Condonation of a 451-day delay in filing an appeal requires a substantiated sufficient cause. Inability to obtain legal advice lacked credibility where a legal notice had been issued shortly after the impugned order. Compliance with a public-notice direction and belief that the matter was concluded indicated acceptance of that order. Unsupported illness claims and a belated request to produce evidence did not establish grounds for condonation.

Corporate guarantees provided to associated enterprises may constitute international transactions, with an arm's-length commission of 0.5% of the guarantee value. Where own funds exceed exempt-income investments, no interest disallowance arises under Rule 8D; administrative disallowance is confined to investments that yielded exempt income, net of voluntary disallowance. Full weighted R&D deduction is available for book-recorded expenditure at an approved in-house facility before Rule 6(7A) introduced expenditure quantification. Forward-contract losses require verification of whether underlying foreign-currency borrowing is on revenue or capital account. Unavailed additional depreciation remains available in the succeeding year. Depreciation and unexplained-money additions based on alleged inflated contract payments depend on coordinated determination of prior-year cash-repayment issues.

Estimated project-profit additions require rejection of regularly maintained accounts or cogent evidence that declared results are unreliable. An ad hoc estimate based on land, construction and overhead costs, comparison with a materially different project, and unsupported site enquiries could not displace audited accounts where no discrepancy was established under Section 145. Differences in project location, duration and treatment of partners' interest also made the profitability comparison unreliable. The reconciled cash-book discrepancy and unrecorded site enquiries provided no evidentiary basis for estimation; deletion of the addition was therefore upheld.