The first proviso to Section 124 of the Customs Act permits oral notice where the person concerned requests it. Compliance depends on whether the noticee received a genuine and effective opportunity to know and answer the allegations, rather than on a formal written show-cause notice. Where the noticee knowingly waives written notice, participates fully in adjudication, and raises no objection before the adjudicating authority, that procedural safeguard cannot ordinarily be revived after an adverse decision. The absence of formal written notice does not by itself create a jurisdictional defect warranting writ intervention in place of the statutory appellate remedy.

Customs-duty recovery imposed as a condition for release of detained gold jewellery remains enforceable where the underlying adjudication order was not challenged. A later writ petition cannot collaterally challenge the duty condition after its implementation; earlier directions for release in accordance with that order do not determine its validity. Warehouse detention charges also remain recoverable absent material showing that they were levied contrary to the governing statutory provisions. Release conditions requiring redemption fine, applicable customs duty and penalty therefore continue to bind the assessee.

Customs Brokers Licensing Regulations permit examination questions on Allied Acts and other laws relevant to EXIM trade and customs clearance, without imposing a numerical allocation between major and Allied Acts. Earlier examination patterns do not bind the expert examining authority. Judicial review of competitive examinations is limited to patent illegality, mala fides, arbitrariness, or manifest error. An expert-verified answer key is presumed correct unless a glaring error is apparent without inferential reasoning; drafting concerns, disputed interpretation, or difficulty do not establish such a defect. Licences or additional attempts do not follow absent a demonstrated patent defect.

Section 129DD permits a revisional authority to annul or modify an appellate order and, absent an express restriction, to remit the matter for fresh adjudication. Revisional review may address overlooked material, unsupported findings, and legal unsustainability without undertaking a wholesale appellate reassessment. In seized-gold matters, Section 123 places the burden of proving lawful, non-smuggled character on the possessor or claimant. A remand does not itself determine confiscation or redemption. Separate notice is unnecessary unless enhanced penalty or redemption fine, or confiscation of higher-value goods, is proposed. Limitation depends on proof of communication of the appellate order and timely objection.

Interest on integrated goods and services tax levied on imports under the Customs Tariff Act requires an express charging provision. For imports made from October 2017 to March 2018, neither the Customs Tariff Act nor the Customs Act authorised interest on that levy. Collection of such interest without statutory authority was therefore impermissible, supporting the assessee's position.

Customs authorities' competence to invoke section 28 of the Customs Act, 1962 to recover additional customs duty on switchgear parts imported between April 2003 and March 2008, after domestic clearance under section 4A of the Central Excise Act, 1944, was challenged. The Supreme Court found no ground to entertain the civil appeals and dismissed them.

Benami character of an agricultural-land purchase was assessed through the source of consideration, possession, custody of title documents, relationships, motive and subsequent conduct. The recorded purchaser's statement disclosed limited financial means and execution of the sale deed at another person's direction for payment. A later claim of personal funding was unsupported, inconsistent with the registered consideration, delayed and implausible. Evidence concerning compensation, its cash withdrawal by a person linked to the alleged beneficial owner, and the parties' connections corroborated the original statement. The purchase was treated as benami, with the recorded purchaser as benamidar and the other person as beneficial owner.

Section 153C requires the requisite satisfaction and consequential action to be taken immediately after, or contemporaneously with, completion of the searched person's Section 153A assessment. Recording the satisfaction note 24 months after those assessments was an inordinate delay that did not meet this jurisdictional timing requirement. The resulting Section 153C proceedings were barred by limitation, rendering the consequential assessments invalid and liable to be quashed.

The proviso governing charitable registration applications empowers the Commissioner to condone delayed applications where reasonable cause is shown and to deem them timely filed. Filing a prior application under an incorrect statutory clause, followed promptly by a corrected Form 10AB application, together with an affidavit and chronology showing no deliberate default, supports reasonable cause. This statutory condonation power operates independently of the general relaxation provided by the CBDT circular. Once delay is condoned, the registration application must be considered afresh on its objects, genuineness of activities, and other applicable registration conditions, without revisiting limitation.

Binding interim judicial directions restraining tax deduction at source on LFC reimbursements prevent a deductor from being treated as an assessee in default for complying with those directions, even where the reimbursements are later held substantively taxable. The employees' substantive tax liability remains unaffected. Such compelled, bona fide compliance constitutes reasonable cause, precluding penalties for failure to deduct tax. Institutional approval processes, personnel changes and e-filing access difficulties may constitute sufficient cause for condoning delayed penalty appeals where there is no deliberate delay, mala fides, prejudice to Revenue, or surviving underlying withholding demand.

Section 12AA registration granted in 2007 remained effective for Assessment Year 2020-21 unless lawfully cancelled or withdrawn. Rejection of a subsequent transitional Form 10A application was distinct from cancellation of the existing registration and did not create a registration gap. The revised Section 12AB framework applied from 1 April 2021 after retrospective omission of the earlier Finance Act, 2020 version, while Section 12A(2) preserved exemption continuity during migration. Exemption under Sections 11 and 12 could not be denied where registration subsisted, earlier-year exemption had been allowed on identical facts, and no breach of charitable conditions was found, subject to verification of other statutory requirements.

Section 12AB registration requires examination of a trust's objects, genuineness of activities and compliance with material laws, but does not permit refusal merely because objects contemplate assistance to a religious community. A specified violation requires material showing actual application of income for that community; an anticipated future disqualification affects exemption assessment, not registration alone. A resolution proposing amendments does not alter a registered trust deed unless duly approved or registered. The statutory enquiry must assess the complete deed, activities, legal compliance and the operative status of any amendments.

Compensation for compulsorily acquired agricultural land in the Hazira Notified Area was not liable to capital gains tax because the land lay outside a municipal area, was used for agricultural operations, and did not constitute a capital asset under the Income-tax Act. The stated requirements for exemption on compulsory acquisition of agricultural land were also satisfied. For separately compensated structures and improvements, the computation required allowance of a reasonable cost of acquisition, with 60% of the compensation identified as the appropriate deduction. The land-compensation addition was deleted and the built-up asset computation required revision.

Rectification under section 154 is confined to mistakes apparent from the record that are obvious, patent and self-evident; it cannot be used to review an assessment or undertake fresh adjudication. A disallowance under section 14A read with Rule 8D requires examination of accounts and satisfaction under section 14A(2) as to the correctness of the taxpayer's claim. Exempt-income and investment figures already on record do not, by themselves, establish an apparent mistake. Accordingly, a fresh section 14A disallowance not made in the original scrutiny assessment lay outside rectification jurisdiction, resulting in quashing of the rectification and deletion of the addition.

Reassessment jurisdiction requires a notice under section 143(2) when an earlier return is requested to be treated as a return filed in response to a section 148 notice and is relied on in computing reassessed income. Non-issuance of that mandatory scrutiny notice invalidates the reassessment. An unexplained-investment addition also requires evidence linking the taxpayer to the alleged payment or acquisition. Digital property-ledger cash entries alone do not establish that link where the registered sale deed identifies another person as purchaser and the taxpayer is neither buyer nor seller; such entries cannot sustain the addition.

A separate DIN-bearing intimation that identifies the DIN of enclosed DRP directions satisfies traceability requirements despite the directions themselves lacking a DIN; retrospective validation provisions also prevent invalidation where the assessment order is identified by DIN. Following a remand requiring verification and hearing, assessment must comply with the limitation applicable to giving effect to an appellate order. A remand for recomputation of arm's length price does not constitute a fresh transfer-pricing reference based on the Assessing Officer's fresh satisfaction and cannot trigger the additional limitation extension. Expiry of that period renders the consequential assessment unsustainable.

Denial of exemption under Section 11 does not permit automatic taxation of an entity's entire gross receipts. Exemption eligibility and income computation are distinct: where exemption is unavailable, taxable income must still be determined under the applicable provisions on a real-income basis. Unless a specific provision requires gross-basis taxation, legitimate expenditure incurred to earn the receipts must be verified for its nature, genuineness and legal admissibility, then allowed in computing net taxable income.

Rule 87 sets the ceiling for annual employer contributions to an approved superannuation fund and cannot cap contributions to a recognised provident fund. Employer provident-fund contributions above 12% may be taxable as salary for employees, while the employer's deduction remains conditional on actual payment under Section 43B. Business expenditure must be proved as incurred wholly and exclusively for business; incomplete, self-made, or unverifiable vouchers may support a reasonable ad hoc disallowance. Illness of the person responsible for tax, finance, and legal matters may constitute sufficient cause for delay where supported by medical evidence.

Faceless assessment communications between the Assessment Unit and Technical Unit must pass through the National Faceless Assessment Centre; an email to the assessee with the centre copied does not establish prescribed receipt by the Assessment Unit. Time taken from a valuation reference until receipt of the valuation report is excludable in computing the assessment limitation period, with the remaining period extended where applicable. Once stamp duty value is disputed and a statutory valuation reference is made, the Assessing Officer must conform to the Valuation Officer's estimate and cannot replace it with stamp duty value. Valuation must be redetermined using appropriate comparables and relevant property-specific evidence.

Registration of a trust cannot be rejected on adverse verification findings without confronting the trust with that material and providing an effective hearing. Donations and expenditure reflected in financial and activity records do not, by themselves, establish that the trust has not commenced activities. The registering authority must independently verify whether activities are carried on and examine their genuineness. A fresh registration application remains permissible after activities commence despite an earlier unappealed rejection, as no statutory bar prevents a further application. The rejection was quashed, requiring fresh adjudication after due opportunity of hearing.