Valuation and content calculations distinguish CIF value-the price paid or payable at importation including the good's cost, insurance and freight-from FOB value, being the price paid or payable when loaded for export, including costs to place it on the carrier. QVC denotes qualifying value content expressed as a percentage. The value of originating and non-originating materials covers such materials used in production in one or both Parties, with the latter expressly including undetermined-origin materials. All costs and values must be recorded and maintained under the Generally Accepted Accounting Principles applicable where the good is produced.

The Customs Tariff (Determination of Origin of Goods under the Free Trade Agreement between India and New Zealand) Rules, 2026 govern origin determination for goods under that agreement. Made under the Customs Tariff Act, 1975, the Rules enter into force on 20 October 2026.

Jurisdiction over a tenant's injunction suit concerning alleged tenancy rights in car-parking spaces is determined from the plaint averments, assumed to be true. Where the plaint alleges tenancy, payment of rent, and interference with possession, the dispute falls within the expression "relating to recovery of possession" under the Presidency Small Cause Courts Act. Its overriding clause prevails over the stated exclusion, while the government-premises exception does not apply without proof that the premises are governed by the relevant eviction law. Composite tenancy may also attract rent-control jurisdiction. The public-premises law does not bar injunction relief where it provides no tenant remedy. Exclusive jurisdiction therefore lies with the Small Causes Court, not the City Civil Court.

Treaty benefits for an item of income may be refused under the principal purpose test where, on all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction that directly or indirectly produced it. A benefit remains available if granting it accords with the object and purpose of the relevant treaty provisions.

The Director (Excise and Taxation), previously appointed under the Punjab Value Added Tax Act, 2005, is appointed as Additional Commissioner of State Tax under the Punjab Goods and Services Tax Act, 2017 with immediate effect. The appointment is made by the Governor of Punjab under section 3 of the Punjab Goods and Services Tax Act, 2017.

Penalty for abetment of improper import of concealed gold requires proof that the person knowingly received, assisted, or otherwise abetted the offending goods. Telephone-call evidence, without reliable corroboration, does not by itself establish knowing receipt or abetment. A third-party statement cannot be relied on when its maker is not made available for cross-examination. The absence of an inculpatory statement by the alleged recipient, incriminating material from the appellant's premises, and admitted knowledge of the goods left the statutory ingredients of abetment unproved; the penalty was unsustainable.

Unexplained expenditure may be added only where it remains unsupported or unexplained on the material on record. Credit-card expenditure was accepted as duly explained in the remand report; therefore, no addition could be sustained for alleged unexplained investment or expenditure. The addition was deleted.

Section 54 deduction applied to capital gains from transfer of a long-term asset comprising a residential house or land appurtenant to it. A structure constructed shortly before the transfer did not preclude relief where its existence was on record and its residential character had not been specifically rejected. Treatment of the asset as an open plot was therefore insufficient to deny the deduction, and the disallowance was deleted.

Unabated assessments under section 153A require incriminating material found during the assessee's own search; third-party material must be addressed through section 153C after prescribed satisfaction. Prior approval under section 153D requires independent, year-specific and assessee-specific consideration of the material and draft assessment orders, rather than a combined mechanical approval. Assessments based on third-party seized material cannot be framed under section 153A or section 144 without following section 153C, including application of its relevant block-period rules. Where an assessment lacks these statutory foundations, penalties arising solely from it do not survive.

Section 2(22)(e) treats gratuitous loans or advances to qualifying shareholders, made merely because of their shareholding, as deemed dividend. An advance given where the shareholder provides collateral security and a personal guarantee for the company's borrowings, thereby conferring a commercial benefit, falls outside that provision. A short-term advance repaid during the year and used to acquire shares in a group concern to facilitate business expansion is commercial rather than gratuitous and is not taxable as deemed dividend.

Additions for estimated profit on alleged unaccounted purchases and for unexplained closing stock require independent evidentiary support beyond a survey notebook recording purchase offers. Where accepted offers are entered in regular books, recorded purchases are corroborated by broker affidavits, and no further material establishes undisclosed transactions or stock, an inference of unaccounted purchases or closing stock lacks an evidentiary basis. Both additions were therefore unsustainable.

Revisionary jurisdiction over a capital-gains assessment cannot be invoked merely because the Commissioner prefers further or different verification. Where computation, sale and purchase materials, and agricultural-land investment were furnished and examined in assessment, the Assessing Officer's partial disallowance of exemption and acceptance of the remaining computation constituted a fact-based plausible view. Non-application of stamp-duty valuation provisions did not itself establish an error unsustainable in law and prejudicial to Revenue. The revisionary order was unsustainable, and the original assessment stood restored.

Reassessment under Section 147 requires a reason to believe that income escaped assessment, founded on fresh tangible material; it cannot be used to review matters examined during the original scrutiny assessment. Reliance on financial documents and other material already available in the original proceedings, without subsequently identified tangible material, amounts to an impermissible change of opinion. An audit objection alone cannot support reopening where it does not disclose fresh material indicating escaped income. Reassessment initiated on that basis is jurisdictionally invalid and liable to be quashed.

Reassessment cannot be sustained where recorded reasons allege unaccounted purchases and sales, but the assessment makes no addition on those allegations. A disallowance for cash payments relating to accounted purchases is disconnected from allegations of unaccounted transactions and cannot independently validate reopening. The formation of a belief that income escaped assessment also requires new tangible material. In the absence of such material and a nexus between recorded reasons and the assessment addition, the reassessment is invalid and liable to be quashed.

Typographical error in an appellate order deleting an unsecured-loan addition arose because the order recorded a lower amount than the amount included in the assessment. The appellate finding noted that no independent enquiry had been conducted and that loan details had not been sought. The deletion was corrected to cover the full unsecured-loan addition, requiring the Assessing Officer to delete the entire amount assessed.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to the interests of Revenue. Multiple assessment notices, taxpayer responses, examination of books, bills, vouchers, financial statements and the tax audit report demonstrated that enquiries had been undertaken. A lack of detailed discussion in the assessment order did not establish absence of enquiry where queries had been raised and answered. Further verification of partners' capital after assessment also supported the existence of examination. As the revisional action identified no specific error causing revenue prejudice and merely sought broad further enquiries, its invocation was invalid; the original assessment was restored.

Structured, curriculum-based skill-development, vocational training, faculty-development and certification programmes qualify as "education" for charitable-purpose purposes. The proviso to section 2(15), directed at general-public-utility activities carried on as trade, commerce or business, does not apply where certification, membership and training receipts are incidental to educational objects rather than evidence of profit-oriented commercial conduct. Absence of disproportionate fees or profit maximisation, application of surplus to charitable objects, and recurring deficits support the educational character. Exemption under sections 11 and 12 is consequently available.

Expenditure disallowance relating to exempt dividend income under section 14A read with Rule 8D(2)(iii) is confined to investments that actually generated income not forming part of total income. Including the entire investment portfolio in the calculation is not justified. The computation should instead use the average value of dividend-yielding investments, subject to verification by the Assessing Officer.

FORM GSTR-1 Table 6 is replaced to separately report exports, supplies to Special Economic Zone units or developers, and deemed exports, with invoice, shipping bill, and tax details. FORM GST RFD-01 and FORM GST RFD-01A are revised to permit deemed export refund claims by either suppliers or recipients. New statements require invoice-level information for accumulated input tax credit refunds under an inverted tax structure and for deemed export refunds. Separate declarations require certifications preventing duplicate refund claims or input tax credit, supported by a repayment undertaking where statutory conditions are not met.

Order VII Rule 11(d) of the Code of Civil Procedure permits rejection of a plaint only where the plaint averments and accompanying documents themselves disclose that the suit is barred by law. A denial of unauthorised construction, coupled with allegations of no show-cause notice or hearing before proposed demolition or sealing, raises issues requiring adjudication. The existence of a statutory appellate remedy under municipal law, without an apparent bar on the face of the plaint, does not by itself justify threshold rejection.