Procedural fairness in insolvency proceedings ordinarily requires that a corporate debtor receive an opportunity to contest the application on merits unless restoration would cause grave prejudice. Where the lapse is limited to failure to file a reply with an interim-moratorium response, a final time-bound opportunity, advance service, a rejoinder opportunity and costs can protect fairness while preserving expeditious disposal.

Pending final disposal of the injunction petition, the direction for investigation by the Serious Fraud Investigation Office was stayed. Questions concerning entitlement to sue in relation to the provident fund trust and alleged defalcation require determination by the Trial Judge; deciding them while affidavits are required for interim relief could prejudice defendants. The ex parte ad interim injunction was continued only until 31 December 2026, with all merits issues reserved for the injunction petition.

Exclusion of a substantial shareholder from management and established economic participation in a quasi-partnership company may constitute oppression where it occurs without due process or justification. Vacation of a director's office for non-attendance requires proof that board-meeting notices were served; continued recognition as a director and the absence of evidence of data misuse or employee solicitation may negate allegations of wrongful competing conduct. Where pre-emption rights have substantially been invoked but a buyout remains incomplete, and shareholder groups seek mutual exit amid irreconcilable differences, a supervised inter se Swiss Challenge process may provide a fair and transparent share-purchase remedy under Section 242.

Evidentiary support for alleged gold and cigarette smuggling was examined through relied-on statements, including purportedly retracted statements, and alleged electronic communications. Documentary proof of the retractions and their delivery to the customs authority was sought, together with the referenced WhatsApp messages and emails. Information on the arrest and prosecution status of a relevant person was also sought. Further submissions and documents were permitted within two weeks, after which the order was reserved.

Indian refractory mortar comprising chromite, magnesite and bentonite is classifiable under CTH 3816 0000, rather than CTH 2610 for chromium ores and concentrates. Applying Rule 1 of the General Rules for Interpretation, Chapter Note 2 to Chapter 26 and the HSN Explanatory Notes, the mixture has a chemical composition distinct from chromite, serves refractory applications and is neither processed for nor used in chromium metallurgical extraction. It therefore falls outside Chapter 26; export duty and penalty do not apply.

Penalty under Section 112(i) of the Customs Act may be imposed for abetment of smuggling where witness statements, tested through cross-examination, are independently corroborated by documentary and financial evidence. Statements recorded under Section 108 are admissible, and cross-examination satisfies natural justice where witnesses maintain their accounts. Evidence of control over the importing entity, bank account, customs clearance, transportation, advances and container movement established participation in smuggling concealed gold and cigarettes. Liability to penalty was sustained, but the penalty imposed on each individual was reduced as excessive in the overall circumstances.

Vitamin and enzyme premixes combined with carriers, fillers, stabilisers and other additives for exclusive animal-feed use fall under Customs Tariff Heading 2309 as preparations of a kind used in animal feeding. Classification depends on the composite goods' character and intended use, read with the Harmonized System Explanatory Notes. The specific tariff headings for vitamins and enzymes do not apply where the products are formulated as animal-feed premixes rather than presented as those substances in their own right.

Shipping-bill amendment applications under Sections 149 and 154 of the Customs Act require consideration when pending objections on maintainability and limitation have not been adjudicated. An amendment request pending since 26 June 2023 was required to be considered in accordance with law within four weeks, ensuring that unresolved threshold objections are addressed through the statutory decision-making process.

Binding coordinate-bench precedent had settled the Customs Tariff classification of nuts, bolts, washers, hand tools and allied scaffolding items, including by quashing materially identical show cause notices. As the settled position had attained finality and its applicability was undisputed, judicial discipline required consistent treatment. The show cause notice alleging misclassification contrary to those binding rulings was therefore unsustainable and stood quashed and set aside.

Advance Authorisation imports of natural rubber are exempt from the port restrictions imposed by Notification No. 32/2015-2020 under Notification No. 11/2015-2020. Following in-principle approval to exit the EOU Scheme, the importer obtained an Advance Authorisation under the Foreign Trade Policy, 2023, enabling imports through Hazira Port. These subsequent approvals were relied on as rendering the challenge to the port-restriction notification unnecessary. The notification's validity had previously been upheld in separate proceedings.

Disallowance under section 40(a)(i) for payments to foreign related entities requires verification of the payments' nature, underlying arrangements, reimbursement and invoicing model, treaty taxability, and whether withholding tax under section 195 applies; absent this examination, fresh adjudication is required. For a debt-free assessee, a separate transfer-pricing adjustment for notional interest on overdue receivables from associated enterprises is unwarranted under the applicable Tribunal precedent and should be deleted. The withholding-tax issue remains subject to factual and legal determination, while the notional-interest adjustment is eliminated.

Transfer-pricing adjustment for notional interest on delayed realisation of receivables from an associated enterprise is unsustainable where the taxpayer is debt-free. A balance-sheet and financial-account review showing no internal or external borrowings establishes that overdue receivables create no incremental financing or working-capital burden. Application of the debt-free-entity principle therefore precludes imputing notional interest, resulting in deletion of the adjustment.

Penalty under Section 270A is unsustainable for a disallowed education-cess deduction claim that was bona fide when made, supported by prevailing judicial precedent, and fully disclosed. Retrospective disallowance of surcharge or cess does not by itself establish under-reporting or misreporting. Section 155(18) provides a beneficial recomputation mechanism to avoid penal consequences; where its prescribed form and procedure were not notified, the assessee had reasonable cause for not invoking that saving proviso. The education-cess penalty is therefore deleted.

Bogus-purchase disallowance may be confined to the estimated gross-profit component where full disallowance is not warranted on the facts. In reassessment proceedings under the Income-tax Act, the accepted approach sustained an addition of 3% of the purchase value, representing the estimated gross-profit element, instead of disallowing the entire value of the alleged bogus purchases.

Penalty under section 271(1)(c) is unsustainable merely because an interest claim under section 36(1)(iii) is partly disallowed. Concealment or furnishing inaccurate particulars requires evidence that income was hidden, particulars were incorrect, erroneous or false, or material facts relevant to computation were withheld. Where the interest claim rests on fully disclosed facts and the disallowance is limited in quantum proceedings, rejection of the claim alone does not establish the statutory default; the penalty is liable to deletion.

Rejection of books of account requires a reasonable basis grounded in identified material defects or discrepancies. Where ledger accounts, invoices, cash-book summaries, stock statements, TCS details, excise-duty challans, audited accounts and creditor details disclose no specific mismatch, purchases of controlled and excisable liquor are supported. An estimated gross-profit rate without reference to past results or comparable liquor businesses is unsustainable. Rejection of the accounts and the turnover-based gross-profit addition were therefore not sustained, and deletion of the addition was upheld in favour of the assessee.

Reassessment under sections 147 and 148 cannot be sustained where the interest-income addition that triggered reopening is deleted in first appeal, and the only surviving estimated expenditure disallowance was not part of the recorded reasons. In those circumstances, the foundational basis for reopening fails, rendering the reassessment invalid despite the surviving disallowance.

Agricultural-income and related expenditure claims concerning agricultural farms and a nursery require fresh verification where supporting records were not produced for the relevant year. Earlier-year acceptance of similar claims after production of ownership records, agricultural receipts and expenditure evidence supports allowing the assessee to furnish complete material. Fair play and natural justice require de novo adjudication by the Assessing Officer after verifying the evidence and providing a reasonable opportunity of hearing.

Condonation of delay requires a bona fide sufficient cause explaining the entire period of delay, although the approach should advance substantial justice. Difficulties in obtaining committee approval did not establish sufficient cause for the prolonged delay. Where no application for condonation of delay in filing a return had been made or decided under the applicable statutory mechanism, the impediment created by the belated return remained unresolved. Effective adjudication was therefore considered academic and infructuous, and the delay was not condoned.

Assessment of a non-searched person under Section 153C requires compliance with the six-year limitation period, calculated with reference to receipt of material or recording of jurisdictional satisfaction. Proceedings are time-barred where the relevant assessment year falls outside that period. A recorded satisfaction note is a jurisdictional requirement; mere reference to receipt and perusal of information does not establish valid assumption of jurisdiction. Approval under Section 153D must demonstrate meaningful consideration of draft assessment orders and cannot be mechanical. Failure of limitation, satisfaction, or reasoned approval requirements renders Section 153C proceedings void ab initio.