Notice under section 143(2) is a mandatory jurisdictional condition for completing a section 153C assessment that departs from a return filed in response to the statutory notice. Complete non-issuance is not a procedural irregularity capable of cure through section 292BB. Applying the view favourable to assessees amid divergent non-jurisdictional decisions, assessments completed under section 153C read with section 143(3) without such notice were quashed. Challenges to additions and other merits remained unadjudicated.

Search-assessment jurisdiction is confined to the statutory ten-year block computed from the search assessment year; assessments outside that period lack jurisdiction. Extension beyond six years requires escaped income represented by an asset: foreign travel expenditure and unsecured loans, being expenditure and liabilities respectively, do not meet that condition. In unabated years, additions must rest on incriminating material found during the search; disclosed transactions, recorded claims, prior-search statements, and material not proving the assessee's payment cannot sustain additions. Search assessments must also be completed within twelve months from the end of the financial year in which the last search authorisation was executed; completion thereafter is time-barred.

Royalty benchmarking for technical know-how requires reliable comparable uncontrolled transactions before applying the Comparable Uncontrolled Price method. Where royalty payments are interrelated with manufacturing and other international transactions, and no evidence establishes an independent royalty transaction or supports CUP comparables, entity-level aggregation under the Transactional Net Margin Method is appropriate; a benefit test alone cannot justify a nil arm's length price. Consistency also requires Revenue to follow an earlier transfer-pricing determination where the royalty agreement, rates, and material facts remain unchanged. The transfer-pricing adjustment on royalty payments was deleted and the Revenue's appeals were dismissed.

Contingency expenses reflected in CTC reports could not be disallowed where they matched the regular books, the books were not rejected, and no evidence showed inflation or fictitious claims; deletion was sustained under the rule of consistency. No disallowance of expenditure relating to exempt income was sustainable because no income exempt under Chapter III was earned; deletion under section 14A read with Rule 8D was sustained. The royalty transfer-pricing adjustment was unsustainable because no prescribed method or proper benchmarking had been applied and relevant joint-venture and support-service documents were not properly considered; deletion was sustained. The Revenue's appeal was dismissed, while the cross-objection was infructuous.

Year-end provisions for audit fees and contractor payments remain deductible where consistently accrued, discharged subsequently, and excess provisions are reversed and offered to tax. Unclaimed interest or capital expenditure recorded in the balance sheet cannot be added merely because it appears as an accrued liability. Section 251 permits remand or setting aside only for ex parte assessments under section 144, making remand for fresh verification impermissible for assessments under section 143(3). No disallowance arises for payments not subject to tax deduction at source or for expenditure relating to exempt income where no exempt income is earned. Income already offered to tax cannot be taxed again; actuarially valued leave-encashment liabilities are deductible; and under-reporting penalty requires valid initiation with recorded satisfaction.

Government departments remain equally bound by limitation requirements in Customs Act appeals. Vague assertions that earlier counsel caused delay do not establish sufficient cause where the department cannot explain file transfer, follow-up, retrieval, or inconsistencies over documents allegedly supplied. Administrative inaction, lethargic internal functioning, and an unsubstantiated effort to attribute delay wholly to counsel cannot justify condonation. In the absence of a reasonable explanation, the delay-condonation application was dismissed and the Customs Act appeal stood disposed of.

Revocation of a Customs Broker licence and forfeiture of security were disproportionate where the broker failed to verify authorisation and KYC documents, but the attempted prohibited export was actively undertaken by its employee and another person. Prompt action against the employee, absence of deliberate or intentional conduct by the broker, and no repeated violations supported retention of the licence with a penalty. Precedents involving repeated breaches and continuous licence misuse did not apply. The High Court upheld the Tribunal's proportionality finding, concluding that no substantial question of law arose.

Multifunctional car radio units designed for vehicle installation, with radio reception and sound-reproduction functions, fall under CTI 8527 21 00 where infotainment features such as touchscreen, Bluetooth, Wi-Fi, USB, camera input, playback and navigation remain supplementary. The absence of in-built speakers does not change that character. Under GRI 2(a), SKD kits comprising components configured solely for assembly into complete units may be classified as the finished unit when, as presented, they possess its essential character; assembly must be limited to minor operations without substantial transformation. Classification remains subject to consignment-level Customs verification and applicable BIS certification.

Section 212(1)(c) requires a demonstrable and reasoned formation of opinion based on cogent, relevant circumstances before an investigation is assigned to SFIO. The statutory order itself must disclose the material considered and the basis for both the investigation and its assignment; later committee minutes, affidavits, or investigation material cannot cure a deficient order. A prior dismissal of a co-accused's petition as premature, with liberty to pursue remedies later, does not create res judicata or bar scrutiny of the initiating action. The SFIO investigation order and consequential proceedings, including the prosecution complaint, were quashed.

Share-purchase consideration paid under a tripartite memorandum, without an obligation to repay or a return for its use, does not satisfy the requirement of disbursement against consideration for time value of money and therefore is not financial debt under the Insolvency and Bankruptcy Code. A claimed oral conversion into an interest-bearing loan requires proof and cannot be established in summary proceedings. Balance-sheet entries, balance confirmations, interest credits and tax deduction at source do not alter the payment's original character or independently prove such an agreement, especially where interest was not paid. Clerical misdescriptions causing no prejudice do not justify interference. Civil remedies remain open.

Insolvency admission for operational debt requires only a summary assessment of whether a plausible, genuine dispute existed before the demand notice; it does not permit a trial of the defence. A returned consignment, contemporaneous WhatsApp communications and a timely demand-notice reply may establish a pre-existing quality dispute. Questions over contractual quality terms, delivery arrangements, laboratory evidence and communication authority require determination in appropriate proceedings rather than summary insolvency adjudication.

Authorised Representatives must obtain prior creditor-class instructions before concurring to resolution-plan timeline extensions under Section 25A(3); procedural character or time sensitivity does not excuse unilateral concurrence. They must also contemporaneously record consultations, including the date, participation or representative character, and views expressed. Emails may evidence consultations, but incomplete records of participation remain a contravention. Cancellation of an insolvency professional's registration requires a penalty proportionate to the misconduct. Where consultation records were incomplete and extensions were uninstructed, but fraud, personal gain, concealment, stakeholder prejudice, or impact on the resolution ou.....

Reasoned adjudicatory orders imposing or affirming FEMA penalties must disclose the evidence and reasons supporting liability. Where the Tribunal accepted the company's explanation for seized Indian and foreign currency, it had to address any further evidence justifying penalties against the appellant; reasons could not be inferred merely from factual narration. The High Court set aside the Tribunal's order because it did not reveal the basis for affirming the penalties, and remanded the appeal for fresh, reasoned adjudication uninfluenced by earlier observations.

Retrospective withdrawal of net SGST reimbursement under IPR 2015 was invalidated as arbitrary, discriminatory and unconstitutional insofar as it affected projects that had invested and commenced production in reliance on the scheme. A policy-review power permitted prospective modification but did not support retrospective deprivation without material showing overriding public interest. Failure to issue or communicate a timely rejection after inspection and verification triggered deemed approval of provisional Priority Sector status; that approval remained subject to reimbursement conditions and quantification. The Negative List did not exclude clinker-based cement manufacture where the specified exception, investment threshold and verification supported eligibility. Net SGST reimbursement must therefore be determined and released under IPR 2015, subject to applicable conditions.

Admission of the drawer's cheque signature triggers presumptions of consideration and discharge of debt, rebuttable on a preponderance of probabilities; an uncorroborated lost-cheque claim supported only by a General Diary entry and stop-payment instructions does not suffice. Lack of loan documentation or tax disclosure does not by itself invalidate a modest hand loan absent a timely, probable challenge to the lender's financial capacity. A proprietary concern lacks separate juridical identity, leaving its proprietor personally liable as cheque drawer. Revision does not permit fresh evidence appraisal absent perversity, complete misreading, or manifest legal error causing miscarriage of justice. Semantic inconsistency concerning financial d.....

Admitted execution of a cheque triggers presumptions of consideration and legally enforceable liability; the drawer must rebut them through a probable defence on a preponderance of probabilities. Inconsistent claims that the cheque was lost or stolen, unsupported challenges to the payee's financial capacity, and non-disclosure of a cash loan in accounts or income-tax returns did not displace that presumption. Bank evidence showing credit to the named payee and a signed return memo established presentation and dishonour, notwithstanding alleged deposit through the payee's firm. "Refer to drawer" falls within dishonour for insufficiency of funds. Revisional jurisdiction does not permit reappreciation of evidence absent perversity, so the concurrent conviction remained undisturbed.

Section 122(1A) of the CGST Act extends penalty exposure to registered and unregistered persons, not only taxable persons, for specified invoice and input tax credit contraventions. Liability requires cumulative proof that the person retained the benefit of the identified transaction and that it was conducted at that person's instance; status as a director, employee, signatory or associate is insufficient. Proceedings must identify the covered underlying contravention and make person-specific, evidence-based findings on both elements, consistent with natural justice and reasoned adjudication. The provision does not create general vicarious liability and applies prospectively only to underlying acts or transactions occurring on or after 1 January 2021.

Corporate-debtor premises may be recovered through the insolvency process when ownership is established and an occupant fails to prove an enforceable tenancy, leasehold interest, or licence. Resolution professionals must obtain custody and protect assets; recovery has a sufficient insolvency nexus for the Adjudicating Authority, while administrative assistance may follow a competent order. Permission to store goods, prolonged occupation, utility records, and business registrations do not by themselves create proprietary or possessory rights. Oral tenancy remains legally possible but requires reliable proof of agreed terms, intention and, where relevant, payment and acceptance of rent. Lease or licence character depends on the arrangement's substance, not labels or exclusive possession alone.

Input tax credit relating to inputs, input services, and capital goods used in construction services must be apportioned and finalised project-wise using carpet-area measures. Excess credit attributable to exempt or unbooked portions must be reversed with applicable interest, while excess reversals may be claimed as credit. Shared inputs, input services, and capital goods must be assigned among projects on a reasonable basis. Integrated-tax credit must first be applied against integrated-tax liability before other tax credits may be used.

Effective from 1 October 2023, the reference in S.O. No. 141-State Tax to registered persons making supply under the composition levy under section 10 is qualified by an express exclusion. Registered persons making supply of specified actionable claims, as defined in section 2(102A), are excluded from the category described by that reference. The amendment applies the existing statutory definition to delimit the relevant class of registered persons.