Tender bidders whose participation rights or accepted bids are displaced by cancellation and revival of an expired earlier contract have standing to challenge the revival. A former contractor that voluntarily participates in an unchallenged replacement tender acquiesces in that process and waives any claim to continued performance under the original contract. Orders made during insolvency and an approved resolution plan do not extend an expired works contract; statutory protection for specified governmental grants does not require contractual renewal. Reviving the contract at original rates without transparent competition after a substantial lapse is arbitrary and contrary to public interest. Remaining works must be awarded through a transparent competitive process.

Section 212(1)(c) requires an opinion, founded on cogent and relevant objective material, that an SFIO investigation is necessary in the public interest. Although the satisfaction is subjective, the assignment order must itself disclose the relevant circumstances, independent application of mind, and reasons for both investigation and SFIO assignment; it remains subject to judicial review. An order merely reciting statutory power, without demonstrable reasons, cannot be cured by later minutes, affidavits, or investigation reports, and invalidates consequential proceedings. Earlier dismissal of a co-accused's writ petition as premature, without merits adjudication, does not create res judicata against pending petitions.

Car Radio Units imported in completely built form are classifiable under Customs Tariff Item 8527 21 00 as motor-vehicle radio-broadcast receivers combined with sound-reproducing apparatus. Under Rule 3(b) of the General Rules for Interpretation, FM/AM reception and sound reproduction determine the units' essential character; touchscreen, connectivity, playback, camera-input and phone-mirroring features remain ancillary. Semi-knocked-down kits are also classifiable under that item where the screen panel, PCBA and cable set are presented together, have the finished unit's essential character, and need only simple assembly, testing and configuration under Rule 2(a). BIS certification requirements remain applicable at import.

Revocation of a customs broker's licence and forfeiture of security are disproportionate responses to an isolated failure to verify an exporter's authorisation and address when the broker had no active role in an attempted prohibited export, promptly dismissed the responsible employee, initiated criminal action, and acted without deliberateness or bad faith. The licensing breach nevertheless justified a monetary penalty. Principles applicable to repeated or continuing violations do not apply where the lapse is isolated and the factual record discloses neither legal error nor perversity.

Section 108 customs summons may be complied with through secure video conferencing where bona fide medical inability prevents long-distance travel. Virtual examination can fulfil the purpose of a customs enquiry while ensuring that summons powers are exercised reasonably, proportionately and without undue hardship, consistent with Articles 14 and 21. Recorded medical injury and willingness to cooperate support this arrangement. Safeguards include secure access, identity verification, videography, visible but non-audible counsel presence, and prior reasoned notice if physical attendance later becomes necessary. Continued cooperation with the investigation remains required.

Condonation of delay in customs appeals requires a plausible, specific and bona fide explanation demonstrating diligence. Limitation law applies equally to Government departments; administrative delay, procedural red tape and unsupported blame on counsel do not constitute sufficient cause. Vague assertions that files were transferred, retrieved, or required further documents, without explaining follow-up or delay at each stage, fail the required standard. The 154-day delay therefore lacked sufficient cause for condonation.

Customs sampling of imported food goods under Section 144 of the Customs Act remains available for examination, classification, valuation, investigation and enforcement of import restrictions. The Customs and food-safety regimes serve concurrent but distinct functions: Customs controls imports and related enforcement, while food-safety law addresses fitness for domestic consumption. Food-safety procedures, including FSSAI clearance processes, do not create exclusive sampling authority or curtail statutory Customs powers. Objections to sampling methods, laboratory testing, chain of custody and report admissibility are to be addressed in Customs adjudication rather than through pre-adjudication writ directions governing resampling, cargo release, testing timelines or demurrage.

Year-end expense provisions maintained under a consistent accrual and reversal practice remain allowable where they represent ascertained liabilities, while cumulative accrued interest beyond the amount claimed cannot be added. Capital expenditure not claimed as a revenue deduction, recorded cash deposits, and income already offered to tax should not be added again. Payments outside tax-deduction-at-source provisions cannot attract withholding disallowance, and no expenditure disallowance arises without exempt income. First appellate remand power does not extend to fresh verification in regular assessments. Actuarially valued leave-encashment liabilities are deductible despite future payment, and valid under-reporting penalty initiation requires recorded satisfaction.

Accepted books of account and reconciliation of project costs with regular books support allowance of contingency expenditure absent evidence that the expenditure was inflated, fictitious, or generated unaccounted cash; internal SOP breaches and isolated failure to respond to verification notices alone do not establish such defects. No disallowance under section 14A read with Rule 8D arises where no exempt Chapter III income is earned; joint-venture profit is governed by section 86. A royalty transfer-pricing adjustment requires use of a prescribed method and proper benchmarking, with joint-venture agreements, support services, and relevant revenue appropriately considered in determining arm's-length pricing.

Royalty paid to an associated enterprise under an agreement supporting manufacturing operations may be benchmarked with related transactions through entity-level TNMM where the transactions are interrelated. Section 92C requires the arm's length price to be determined using a prescribed method. CUP requires comparable uncontrolled transactions; without them, it cannot support a royalty adjustment. A nil royalty determination based solely on a benefit test is impermissible. Where the agreement, technical support and material facts remain unchanged from prior years, consistency supports continued use of entity-level TNMM.

Foreign tax credit under section 90 and Article 23 of the India-Germany DTAA provides relief from double taxation, while Rule 128 prescribes the claim procedure. Where Form No. 67 is filed within the prescribed time, an incorrect DTAA article reference is a curable defect if later rectified. Rule 128(9) is directory and does not justify denying foreign tax credit solely because a corrected form is filed late. Credit remains subject to verification of foreign tax payment and eligibility under the applicable provisions.

Search assessments under section 153A must remain within the applicable ten-year assessment block; years outside it cannot be assessed under that provision. The extended block requires material showing escaped income represented by a qualifying asset, so foreign-travel expenditure and unsecured loans, being liabilities, do not satisfy that jurisdictional condition. For completed, unabated years, additions require incriminating material unearthed during the search; disclosed books, recorded expenditure, and pre-existing investigation statements are insufficient. Section 153B also requires completion within the prescribed limitation period; an assessment completed after that deadline is time-barred. These requirements can invalidate assessments and related additions that fail the relevant condition.

Issuance of notice under section 143(2) is a mandatory jurisdictional condition before income returned in response to a section 153C notice may be assessed under section 143(3). Complete absence of that notice is not a procedural defect curable under section 292BB. Where competing interpretations of a taxing provision exist and no jurisdictional High Court ruling applies, the interpretation favourable to the assessee governs. Assessments completed without the mandatory notice are invalid and liable to be quashed.

Reassessment initiated on information from the Insight portal and investigation wing was treated as valid notwithstanding allegations of borrowed satisfaction and inadequate independent enquiry, as the first-appellate findings disclosed no infirmity. Where goods were actually received but invoiced through fictitious suppliers, the recorded purchase expenditure was regarded as inflated. Disallowance of an appropriate portion of the purchase price was permissible to account for that inflation, and the 25% disallowance was maintained. The reassessment and addition for inflated purchases consequently remained undisturbed.

Actual service of a notice under Section 148, in addition to valid issuance, is a jurisdictional condition precedent to reassessment under Section 147. The Revenue must establish service through postal receipts, acknowledgements, or other reliable evidence. Where no service evidence is available, reassessment is void ab initio. An assessee's response to a later notice, return filing, or participation in assessment proceedings cannot confer jurisdiction by consent, waiver, or estoppel. Consequently, revision founded on an invalid reassessment cannot validly survive.

Rectification under Section 254(2) is limited to mistakes apparent from the record and cannot reopen findings reached on material already considered. Revision under Section 263 remained sustainable because the assessment order was found erroneous and prejudicial to Revenue, based not only on a discrepancy in the donation receipt but also on concerns over the genuineness of political entities, alleged bogus political donations, and inadequate assessment inquiry into eligibility under Section 80GGC. Receipts and bank statements did not establish any manifest error warranting rectification; consequently, Section 254(2) relief was unavailable.

Third-party seized material recovered during a coordinated search must be used against an assessee through the assessment mechanism under Section 153C, rather than through Section 153A where the material was seized from another person's premises. This preserves the statutory route governing material belonging to or relating to a third party. A protective addition under Section 68 cannot continue once the corresponding substantive addition has been quashed, because the protective assessment has no independent basis after the substantive liability fails.

Section 275(1)(c) requires a penalty order to be passed within six months from the end of the month in which notice initiating penalty proceedings is issued. As the notice for penalty under section 271D was issued in January 2021, the limitation period expired in July 2021. The penalty order passed in March 2022 was time-barred and invalid. The first appellate order was consequently set aside in favour of the assessee.

Comparable Uncontrolled Price benchmarking requires an identifiable uncontrolled transaction adjusted for material differences; a bank prime lending rate plus an estimated premium, and controlled related-party transactions, cannot supply the benchmark. Secured bank borrowing and unrelated unsecured loans supported the related-party interest rate, leaving no transfer-pricing adjustment. Where own interest-free funds exceed investments or advances and the Revenue does not prove diversion of borrowings, the interest-free funds presumption removes interest disallowance under rule 8D and for interest-free advances; fund-flow evidence or a linking chart is unnecessary. Administrative expenditure may nevertheless be disallowed where exempt income is earned, recorded dissatisfaction supports the computation, and the amount does not exceed exempt income.

Documentary proof of lender identity, creditworthiness and transaction genuineness, including confirmations, financial records and banking-channel receipt, interest and repayment, discharges the assessee's onus for unsecured loan credits. A general allegation that lenders are accommodation-entry providers, without material linking the assessee or transactions to that arrangement or rebutting the evidence, does not sustain additions for loan credits or repayments. Unexplained-expenditure additions for alleged interest or commission require evidence that expenditure was actually incurred; presumptions, estimates, or consequential allegations arising from loan transactions are insufficient.