Section 80IA/80IB deductions were available to a new hydraulic power steering gear undertaking that operated as an integrated, independent manufacturing unit and commenced production before the statutory cut-off. Separate premises, new machinery, capital, workforce, power load, production, accounts, sales and excise records supported its independent character; subsequent machinery additions merely increased capacity. Initial-year eligibility continued through consecutive eligible years where no material facts changed. Depreciation was allowable for machinery installed and kept ready for business use, as passive use satisfies the business-use requirement where contrary evidence is absent. Deductions and depreciation were allowed for the relevant years.

Recording of satisfaction by the Assessing Officer during assessment is required before penalty proceedings under section 271D can be initiated for cash receipt of immovable-property sale consideration. Where jurisdictionally binding precedent requires this satisfaction, a contrary Tribunal view based on law binding in another jurisdiction does not govern. When High Court interpretations diverge, the interpretation favourable to the assessee applies. On that basis, deletion of the penalty was sustained, the Revenue's appeal was dismissed, and the assessee's cross-objection became infructuous.

Transitional reassessment notices must be issued within the surviving limitation available under the legal fiction, after prescribed exclusions. Where the new-regime notice is issued after that period, the resulting reassessment is void from inception, non est and incapable of revision because a valid subsisting assessment is a condition precedent for revision. Revision also requires both an erroneous assessment and prejudice to Revenue. Inquiry into exempt long-term capital gains supported by transaction records, contract notes, demat evidence, banking trail and securities transaction tax cannot be treated as erroneous merely because the inquiry was not extensively recorded or further inquiry is considered desirable.

Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.

Section 271(1)(c) treats concealment of income and furnishing inaccurate particulars as distinct penal defaults, requiring clear identification and proof of the specific charge. Mere non-disclosure does not establish inaccurate particulars unless the return contains incorrect or false details. An explanation offered during assessment, not found false and used to quantify the addition, may support bona fides and prevent application of Explanation 1. Although tax penalties do not require proof of mens rea, an addition alone does not make penalty automatic. On these facts, the absence of a specific default and failure to satisfy Explanation 1 led to deletion of the penalty.

Direct appeals to the Tribunal against an Assessing Officer's rectification order under section 154 are not maintainable where the statutory appeal to the Commissioner (Appeals) has not first been filed. The prescribed appellate sequence requires the aggrieved taxpayer to pursue the first appellate remedy before approaching the Tribunal. An erroneous reference in Form No. 36 to a Commissioner (Appeals) order does not convert the proceeding into a valid appeal against that order.

Capital grants, subsidies and consumer contributions reduce the actual cost or written-down value of relevant assets for depreciation. Where not directly attributable to a particular asset, they require allocation among the affected assets at their respective depreciation rates. Book-profit adjustments for such grants, including subsidy grants received in advance, require an identified clause in the Explanation to section 115JB(2); treatment under normal tax provisions alone is insufficient. Borrowing-cost capitalisation depends on direct attribution to qualifying capital projects and cannot rest on an unsupported assumed historical rate or unsubstantiated accounting-method change. Assistance for beneficiary-owned solar systems is revenue i.....

Provisional release of seized Ketamine Hydrochloride for export was warranted where a fresh export authorisation covered the same goods after the original authorisation had expired following replacement of the shipment batch. The High Court treated the delay in obtaining the fresh authorisation as technical because the goods remained unexported and the licensing authority had accepted the new authorisation as valid. Customs could not deny its effect merely because the licensing authority had not expressly authorised release of the seized goods. Union departments must maintain consistent positions on the same export transaction. The rejection of provisional release was quashed, subject to a Customs deposit, while adjudication and criminal proceedings remained unaffected.

Capital goods intended for use in a warehouse authorised to undertake manufacture or other operations may remain warehoused until clearance under the amended customs framework. Interest on warehoused goods is confined to residuary goods and does not apply to capital goods falling within the specified category. Intended use is determined when the goods are imported and warehoused; actual subsequent use is not required. Solar modules intended for a solar power project retained their character as capital goods despite becoming surplus because of later design and layout changes. A circular concerning clearance for non-manufacturing purposes cannot impose interest where the statute does not provide for it.

Royalty and licence fees may be included in the customs transaction value only where Revenue establishes a direct and proximate relationship with the imported goods and proves that payment is a condition of their sale. The explanation concerning post-import processing does not independently expand these requirements. Royalties payable for technology transfer, intellectual property, or post-import manufacturing rights are not linked to imports merely through a broad commercial connection. Where royalty arises from manufacture and sale of finished products, is neither conditional on component imports nor calculated by their value or quantity, it is not includible in the assessable value of imported components.

Self-assessed bills of entry constitute appealable assessment orders, even without departmental reassessment, a lis or a speaking order. Waiving notice and personal hearing for expedited adjudication does not, absent an informed and express surrender, waive the independent statutory right to challenge tariff classification. In reclassifying Rivet Mobile Contact, Revenue bears the burden of proof; evidence of silver content alone does not resolve classification where dedicated design and use establish its essential character as an electrical contact. The product is excluded from Chapter 71 and classifiable under CTH 8538. Without misdeclaration of description, quantity or value, a bona fide classification dispute alone does not support confiscation, redemption fine or penalty.

Actual-user compliance under an end-use customs exemption is met where imported wind-operated electricity generator parts are used exclusively to erect and commission windmills in the specified turnkey project. The condition requires ultimate use for the prescribed purpose but does not expressly bar movement of components to the project site or transfer of title under supply contracts before final assembly. Continuous ownership by the importer until commissioning is not required where the importer remains responsible for installation and commissioning. Contractual transfer before final assembly therefore does not, by itself, breach the concessional exemption condition.

Medical-device parts and accessories suitable solely or principally for use with a Cell Separator are classifiable with that device under Chapter 90. The residual tariff entry for parts and accessories applies only where the goods are not otherwise specified or included within that Chapter. AMICUS Platelet Kits and similar Cell Separator accessories therefore fall under CTH 9018 rather than the residual CTH 9033 classification. This classification attracts IGST at the rate prescribed for medical devices and related goods under the relevant Schedule entry.

Refusal of a private bonded warehouse licence for cut and polished diamonds cannot rest solely on prior customs adjudication imposing duty, redemption fine and monetary penalties. Regulation 3(2)(c) disqualifies an applicant penalised for an offence under the Customs Act, while civil contraventions attracting monetary penalties remain distinct from criminal offences liable to prosecution. On that distinction, prior adjudication orders did not establish the required disqualification, so the refusal was set aside and the licence application could not be rejected on that basis.

DGFT interpretation of the Foreign Trade Policy is final and binding on Customs, including whether entities qualify as group companies. Common directorial voting control meeting the prescribed threshold permits use of a group company's duty credit scrips and service-export earnings towards an importer's EPCG export obligation. Capital goods for service-sector exemptions include equipment and accessories required directly or indirectly to render services; helicopter parts used for operational transport supporting remote infrastructure projects may qualify on that basis. Aviation permission describing private use does not by itself establish personal use. Extended limitation requires deliberate non-disclosure intended to evade duty, and prior departmental knowledge negates wilful suppression.

At the interim stage, Regulation 18(3) did not prima facie require financial creditors in a class to obtain prior intra-class majority approval through the Authorised Representative before seeking placement of a CoC agenda, where the prescribed voting threshold was met. Suspension of an insolvency professional's registration removes eligibility to act in all ongoing insolvency assignments, not only the process connected with the alleged misconduct. Intimation to other CoCs and the Adjudicating Authority gives effect to that consequence and remains distinct from a CoC's replacement power. Interim stay required a prima facie case, balance of convenience and irreparable injury, assessed with public-interest caution; as these were not established, the stay was declined pending appeal.

Section 45(1) of the PMLA permits regular bail for an accused who is sick or infirm. "Sick" and "infirm" operate disjunctively and do not require terminal illness, irreversible deterioration, imminent danger to life, surgery, or hospitalisation. Infirmity may result from substantial physical impairment without an immediate life-threatening condition. Medical needs must be assessed cumulatively, including coexisting conditions and the need for structured, continuous, supervised rehabilitation. Hospital referrals, diagnostic tests, or conservative management do not alone establish adequate care; the material issue is whether custody can effectively deliver the prescribed treatment. Bail safeguards may address risks to witnesses, evidence, investigation, and trial.

Approval of a resolution plan settling confirmed government dues causes the corporate debtor's pending excise appeal to abate. Excise duty remains payable by persons who clear processed fabrics, even where they are not manufacturers, because liability attaches on clearance; however, the transferee's specific penalty concerning stock was not sustained. Pre-clearance grading, cartage, brokerage and stock-interest expenses form part of assessable value where goods enter wholesale trade only on sale to independent buyers, sustaining the related duty and interest. Penalty for intent to evade duty requires findings of prescribed conduct and cannot rest solely on inadmissible valuation deductions. Penalties relating to confiscable goods likewise require their statutory basis; general penalties may instead apply to proven participation in duty evasion.

Classification of railway-specific printed forms turns on their character as products of the printing industry under Chapter 49 rather than paper stationery under Chapter 48. Central excise liability also depends on marketability: forms bearing departmental particulars and usable only for internal railway purposes are not marketable unless the Revenue proves that they can be bought and sold for consideration. Earlier Tribunal decisions on identical goods applied this marketability test and treated the absence of such proof as defeating excise duty, consequential interest, and penalty.

Advance disbursement of September 2026 salary, wages and pensions is authorised on 25 September for central government employees, industrial employees and pensioners because of the proposed bank strike. Payments constitute advance payments and must be adjusted after full monthly entitlements are determined, with any adjustment made from October salary or wages. End-of-month banking transactions should, where feasible, be processed in advance.