Recovery of the balance disputed tax demand arising from transfer-pricing adjustments was stayed pending appeal, conditional on deposit of 20% of the outstanding demand after excluding proportionate demand relating to services claimed to have been rendered to an associated enterprise. The stay operates for 180 days or until appeal disposal, whichever occurs first, subject to meeting the deposit condition and cooperating in early appeal disposal. No merits determination was made on the transfer-pricing additions.

Section 144C requires a draft assessment order before a final reassessment order imposes a prejudicial variation on a non-resident eligible assessee. Following the amendment to the definition of eligible assessee, non-residents other than companies are expressly covered. The draft procedure allows the assessee to accept the variation or seek directions from the Dispute Resolution Panel. Direct issuance of a final reassessment order without a draft order deprives the assessee of that statutory remedy. Such non-compliance is a jurisdictional defect rather than a curable procedural irregularity, rendering the final reassessment order invalid.

Extended limitation for recovering wrongly exempted Special Additional Duty was sustained where, following amendment of the relevant Schedule, the exemption was unavailable and RMS-facilitated imports were cleared on the importer's declaration. The Special Additional Duty demand and its appropriation consequently remained valid. Interest under Section 28AA and penalty under Section 114A on the confirmed duty demand were unsustainable under affirmed precedent and subsequent consistent Tribunal decisions, and were set aside. The modified order retained duty recovery while removing interest and penalty, with consequential relief in accordance with law.

Cross-segment derivatives trading was treated prima facie as manipulative where connected companies moved futures prices through aggressive orders while holding larger, sentimentally opposite options positions and pre-positioned options orders. Artificial futures-price movements enabled favourable options execution, while cancelled, inexecutable futures orders added deceptive order-book depth. Repeated deliberate futures losses coupled with greater options gains were considered inconsistent with legitimate hedging, arbitrage, speculation, or rational profit-maximising conduct. Company directors responsible for business conduct faced a rebuttable presumption of vicarious liability and joint-and-several impounding of gains attributable to their companies. Interim directions restricted market access, preserved assets and gains, and required asset disclosures pending investigation.

Dismissal of employees through composite charge-sheet-cum-dismissal orders without a disciplinary inquiry breached natural justice, and the findings that termination was illegal remained undisturbed. Labour awards made before commencement of CIRP crystallised the employees' compensation entitlement and were not displaced by a subsequently approved resolution plan. Court-directed deposits securing those awards represented the employees' entitlement once the awards attained finality; failure to seek withdrawal before CIRP did not entitle new management to the funds. Employees could withdraw the deposited compensation and accrued interest, but had no further service-related claims.

Look Out Circulars constitute coercive restraints on the right to travel abroad and require a continuing factual basis; a pending money-laundering investigation alone does not justify their routine continuation. Relevant considerations include compliance with summons, provision of requested material, prior travel without evasion, absence of court-imposed travel restrictions, and lack of evidence of abscondence, non-compliance or obstruction. Travel-related safeguards may require advance disclosure of travel particulars, a valid email address and full cooperation with the investigation to ensure continued availability.

Provisional attachment of cash as proceeds of crime requires a demonstrated nexus between the property and the scheduled offence. Evidence of a double-trip mechanism, supported by the truck driver's statement, showed excise-duty evasion through repeated use of transport documents. The warehouse owner did not independently corroborate the claimed bank withdrawal or receipts from traders; a cash book retained in the owner's custody lacked independent evidentiary value. The absence of bank records, investigative material, and increased declared income established the nexus between the seized cash and illicit country-liquor transactions, so the cash was treated as proceeds of crime and the attachment remained in force.

Known departmental attachments in a SARFAESI auction constitute encumbrances where entered in the encumbrance certificate and restrict alienation, transfer and further charges. Rules 9(6) to 9(10) require disclosure of known encumbrances and allow delivery free of them only after deposit of the amount required for discharge. Secured-creditor priority over Government dues governs recovery of secured debt but does not displace that mandatory sale procedure. Accordingly, a disclosed departmental attachment cannot be removed from the encumbrance certificate, nor can an auction purchaser avoid the associated dues, unless they are discharged. A secured creditor is not functus officio while any part of its debt remains unrecovered and enforcement continues.

Possession of unused premises in a non-operational Special Economic Zone unit was separated from the parties' monetary claims to facilitate use by a viable entrepreneur. The applicable rent-control, Special Economic Zone, or public-premises eviction regime was treated as academic and left open. Claims for rent, maintenance, termination, improvements and damages were referred to arbitration, while the respondent was required to vacate after supervised removal of movables and evaluation of improvements.

Circumstantial evidence can sustain murder, conspiracy and destruction-of-evidence convictions only when the proved circumstances form a complete chain excluding every reasonable hypothesis of innocence. Electronic communications may be authenticated through certificates and responsible service-provider testimony despite non-prescribed certificate formats or authorised data transfers. Discovery pursuant to disclosure statements, deleted communications, unexplained contact patterns, conduct and false alibis may complete that chain. Article 161 clemency remains a distinct constitutional power, wider than statutory remission, permitting individual pardon, reprieve, remission or commutation on ministerial advice and unaffected by statutory remission mechanisms.

Documented cash purchases of fruits supported by ledger accounts, sale invoices and bank-account extracts constitute explained business expenditure where the supplier dealings are regular, and corresponding receipts and transactions have been disclosed. Failure to give due cognisance to this evidence cannot sustain an addition for unexplained expenditure under Section 69C. The expenditure is treated as arising from disclosed business transactions rather than unexplained spending.

Cash deposits in a taxpayer's bank account were explained as consultancy fees collected from identified clients and already included in gross receipts reported in the income-tax return. Cash vouchers recorded the clients and amounts collected, providing documentary support for the deposits' source. Because that evidence was not rebutted, the deposits could not be sustained as unexplained, and the corresponding addition was deleted.

Penalty for under-reporting of income under section 270A was unsustainable where the assessment order initiated penalty proceedings under section 271(1)(c), an inapplicable provision for the relevant assessment year beginning on or after 1 April 2017. Initiation under the obsolete provision demonstrated non-application of mind and vitiated the penalty proceedings at their foundation. Consequently, the penalty levied under section 270A was deleted.

Presumptive-tax addition based on bank credits required examination of the bank statements and ledger accounts reportedly filed in appellate proceedings. Although the appellate order recorded that no evidence supporting the bank deposits had been filed, it also reproduced the taxpayer's submission that bank-account statements and ledger-account copies were enclosed. Verification of the underlying deposits and a fresh determination of the addition were required, after affording the taxpayer an opportunity of hearing.

Fresh opportunity of hearing was granted for reassessment of cash deposits during demonetisation, estimated business income and disallowed salary-related claims. The assessee had not assisted during the assessment or first appellate proceedings; a further opportunity was therefore permitted to substantiate the claims through written submissions and documentary evidence. The assessment was remanded for fresh adjudication after a hearing, without determination of the merits of the additions or claims.

The 25% corporate tax rate for Assessment Year 2018-19 applied where a company's total turnover in the previous year 2015-16 remained below Rs. 50 crore. Total revenue of Rs. 48.72 crore, comprising Rs. 46.79 crore from operations and Rs. 1.93 crore as other income, remained within that threshold. The company was consequently subject to tax at 25% rather than 30%.

Revisionary jurisdiction under Section 263 requires a demonstrated error in the assessment order that is prejudicial to Revenue interests. Where the taxpayer has furnished complete particulars of legal and professional expenses, including their nature and purpose, and the assessment follows adequate enquiry, a revisional authority must identify a specific defect and explain the resulting prejudice. The power cannot be invoked merely to seek further verification or to conduct a fishing and roving enquiry. On these stated facts, revision of the assessment concerning the expense allowability was unjustified.

Interest awarded under section 28 of the Land Acquisition Act forms part of enhanced compensation and, unlike section 34 interest for delayed payment, does not become income from other sources. Amendments governing taxation of compensation interest do not alter that character. Revisionary jurisdiction under section 263 is unavailable where the Assessing Officer specifically examined the issue and adopted a legally possible view on a debatable question. An audit objection alone cannot render the assessment erroneous and prejudicial to the Revenue, while an unreasoned dismissal of a special leave petition is not binding law.

Section 153C treats the date on which seized material is handed over to the jurisdictional Assessing Officer and satisfaction is recorded as the deemed search date for applying the six-year assessment block under Section 153A. Where handover occurred during financial year 2021-22, only assessment years 2016-17 through 2021-22 fell within the assessable block. Assessment year 2015-16 therefore lay outside the prescribed period, rendering proceedings for that year time-barred and beyond jurisdiction.

Additions for unexplained cash credits in a concluded, unabated search assessment require incriminating material actually found during the search. An investigation report alleging accommodation entries, or a statement recorded during search that is unsupported by seized material, does not meet that requirement. Expiry of the period for issuing a scrutiny notice means the assessment remains concluded; non-filing of the original return does not make it pending. Nor does a return filed in response to a search-assessment notice itself become incriminating material. Consequently, an unexplained cash-credit addition resting only on those sources is unsustainable and liable to deletion.