Foreign tax credit on foreign dividend income cannot be denied solely because the prescribed form was furnished after the original-return due date but before the revised return and the end of the assessment year. Where the governing statute imposes no filing deadline and the procedural rule neither links delay to denial nor lists delayed filing as a disqualifying circumstance, the filing requirement operates as directory. Rectification is available where processing annexures recognise foreign tax credit as available but the computation simultaneously records it as nil, since that internal inconsistency is a mistake apparent from the record. The credit is to be allowed, while the processing adjustment remains open to challenge.

Uncorroborated statements recorded during a survey cannot alone support an addition for estimated income as unexplained money where no unrecorded money or specified valuable article is found, audited books are not shown incorrect, and no incriminating material exists. The addition was deleted. Delayed electronic furnishing of a tax audit report may constitute reasonable cause when accounts were audited and the report signed within time, but uploading was omitted due to the auditor's illness, without intent to evade tax. The related penalty was deleted.

Penalty for deemed income based solely on stamp-duty valuation is not justified where the taxpayer disclosed the registered deed, bank statements and payment details, and there is no finding that actual consideration exceeded the stated amount or that disclosures were false. Although statutory substitution of stamp-duty value can support an assessment addition, it does not alone establish concealment or inaccurate particulars, and the conditions for penalty are not met where the explanation is not found false. Acceptance of the addition does not admit that the stated consideration was untrue. Conversely, a notice expressly alleging concealment provides a specific charge when the penalty rests on that same allegation.

Penalty for under-reported income is not automatically attracted merely because a first return is filed in response to a reassessment notice and accepted without variation. The statutory trigger must be read with the exclusion for a bona fide explanation and full disclosure of material facts. The use of "may" preserves discretion in imposing penalty. Relevant indicators of bona fides include audit-related delay, an undisposed request to file the return, prompt filing after notice, verified declared figures, and payment of tax and interest. Treating bona fides as irrelevant without reasoned consideration is inconsistent with this framework; on the stated facts, the penalty was deleted.

Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.

Conversion of a capital asset into stock-in-trade under a joint development arrangement requires proof that the asset entered the assessee's business stock; executing such an arrangement alone, particularly without a real-estate business, does not establish conversion. On that basis, the long-term capital-gains addition was deleted. A transfer of flats to a spouse without actual consideration, made to safeguard property interests, is not a sale merely because a sale deed records consideration. The deed recital cannot establish income received, and the business-income addition was deleted.

Reassessment under sections 148A(b) and 148A(d) requires the reasons recorded for reopening to correspond with the information and grounds put to the assessee for explanation. Where a notice treated land as undisclosed and an unexplained investment, but the subsequent satisfaction accepted its disclosure and instead questioned the source of acquisition funds, the basis of reopening changed completely. Fresh or supplementary reasons cannot sustain reassessment without prior notice under section 148A(b). The Tribunal therefore quashed the reassessment, leaving the merits of the addition unadjudicated.

Non-conformity of a scrutiny notice under section 143(2) with the CBDT-prescribed format is treated as a procedural defect curable under section 292B, rather than one invalidating the notice or consequential assessment. In appellate proceedings, material admitted as additional evidence must be made available to the Assessing Officer for examination under Rule 46A. Deletions based on unexamined material, or made without recorded reasons, require reconsideration through a fresh, reasoned assessment after hearing the assessee. The notice challenge was rejected, while disputed additions were remitted for de novo assessment.

Tax deduction at source on interest arises on credit or payment, whichever occurs first; a brought-forward interest liability does not itself constitute a current-year credit. The real income doctrine requires objectively established contemporaneous circumstances showing that income did not accrue, rather than merely an absence of accounting entries. Unexplained-expenditure provisions apply to expenditure incurred in the relevant financial year and do not extend to an earlier capital advance merely carried forward, particularly where recorded in regular books. A capital work-in-progress write-off already added back in computing business income should not be added again, as this would result in double taxation. Interest capitalised to work-in-progress is not subject to disallowance where tax was deducted and deposited within the prescribed return-filing timeline.

The test of human probabilities permits tax authorities to look beyond documentary evidence and banking-channel payments when assessing the real nature of a political contribution. Donation receipts and bank payments did not prove genuineness where investigation material, statements, bank-trail analysis, and the recipient party's modus operandi showed systematic fund layering for accommodation entries. The apparent transaction was not a genuine political contribution; the claimed deduction was denied, the consequential addition sustained, and the assessee's appeal dismissed.

Section 50B prescribes a self-contained method for computing capital gains on a slump sale, including fair market value and net worth under Rule 11UAE. Where no defect in the valuation methodology or non-compliance with Rule 11UAE is identified, the Assessing Officer cannot substitute a different valuation; deletion of the resulting capital-gains addition was confirmed. A capital-gains addition made without a proper show-cause notice also breached CBDT Instruction No. 20/2015 and was independently unsustainable. The Revenue's appeal was dismissed.

For capital gains exemption under section 54F, a shop-cum-office verified as commercial cannot be treated as an additional residential house when applying the ownership condition. The denial based on its classification as a residential house was therefore removed, subject to satisfaction of the remaining statutory conditions. For section 54B, agricultural land does not lose its agricultural character merely because it is situated in an urban area. Reinvestment relief was available to the extent supported by purchase deeds and other documentary evidence establishing eligible investment.

MEIS benefit processing requires a shipping bill's Reward declaration, inadvertently entered as 'N', to be corrected to 'Y' in the EDI system after Customs has made the corresponding manual correction. The amended shipping bills must then be electronically transmitted to DGFT under the prescribed public-notice procedure so that the MEIS claim can be implemented. Administrative technology must facilitate, rather than obstruct, a rectifiable procedural correction; the specified Customs and DGFT actions are to be completed within four weeks of communication.

Revenue must establish tariff reclassification through evidence of each imported article's objective characteristics, applicable tariff entries, Section Notes and Explanatory Notes; representative sampling, undisclosed website material and unreasoned end-use assertions were insufficient. The proposed reclassification and consequential denial of concessional duty failed. Extended limitation required pleaded and proven collusion, wilful misstatement or suppression; a corrigendum could not add new articles or bills of entry, and charges first introduced through it ran from its date. The extended-period demand was unavailable. Duty determination had to reconcile annexures and appropriate verified payments, so the unreconciled demand failed. Inc.....

Section 28 permits recovery of unpaid or short-paid anti-dumping duty through a demand notice without first challenging the importer's self-assessment. This recovery mechanism is distinct from refund proceedings, where an unmodified self-assessment may restrict relief. Anti-dumping duty imposed under the Customs Tariff Act is treated as customs duty for calculating IGST on imported goods; IGST therefore applies to the aggregate value including such duty. The maximum penalty for non-payment is governed by the statutory ceiling applicable on the date of import, and a subsequently enhanced ceiling cannot apply retrospectively.

Minimum Import Price restrictions regulate imports entering the domestic market for home consumption and do not apply to goods warehoused under Customs control exclusively for re-export. A declared value below the Minimum Import Price, or higher National Import Database data alone, does not establish undervaluation without corroborative evidence of under-invoicing, additional consideration, or deliberate misdeclaration. Where the Minimum Import Price premise does not apply, rejection and redetermination of declared value cannot survive. The declared assessable value was restored, consequential confiscation, redemption fine and penalty were set aside, and re-export was permitted subject to procedural requirements.

Pine Bark Extract and Grape Seed Extract are classified as vegetable extracts under Heading 1302 rather than as food preparations under Heading 2106. Multi-stage extraction, concentration, drying, or adsorption does not exclude goods from Heading 1302 unless processing selectively enriches or depletes particular compounds or compound classes beyond ordinary solvent extraction. As single-ingredient botanical extracts imported in bulk as raw materials, the products were not finished food or dietary supplements for direct consumption. Because neither product was specifically enumerated within Heading 1302, both fall under the residual tariff item for other vegetable extracts, Customs Tariff Item 1302 19 39.

Pendency of arbitration over underlying loan transactions does not prevent initiation of wilful-defaulter proceedings where borrowers are alleged to have disposed of assets securing credit facilities without lender approval. Such alleged conduct falls within the RBI Directions, 2024, and a show-cause notice founded on identified assets and supplied documentary material represents only a prima facie view. Borrowers must respond before the competent committees decide the matter and may use the available review process thereafter. The challenge was treated as premature; the notice remained in force and the response period was extended by two weeks.

Greenhouses cleared from the factory in ready-to-assemble condition fall under the specific tariff entry for greenhouses in ready-to-assemble sets rather than the general entry for plant growth chambers, applying Rule 3(a)'s preference for the most specific description. An amendment extending the normal excise-demand limitation period from one year to two years operates prospectively absent express retrospective effect and cannot revive a demand already time-barred. On that limitation basis, the duty demand, interest and penalty were set aside.

Portfolio-management reforms replace the 2020 framework and expand investments into IPOs, primary-market debt, listed overseas equity and debt, and direct plans of Indian mutual fund schemes. Investment-grade unlisted non-convertible debt may comprise up to 10 per cent of client assets under management with client consent. Independent Fund Managers may operate with registered portfolio managers, which retain responsibility and liability. Accredited-investor eligibility is broadened, while specified compliance requirements are relaxed where adequate audit trails and internal controls exist.