Minimum Import Price restrictions do not apply to goods placed in bonded warehousing solely for re-export where no intended diversion to home consumption is shown. A policy-based minimum price, without evidence of additional consideration, under-invoicing, concealment, or discrepancy, cannot alone displace the declared transaction value. Comparable import data cannot sustain value redetermination once that premise fails. In the absence of deliberate misdeclaration or mala fide undervaluation, goods are not liable to confiscation, redemption fine, or penalty. Such transactions retain their character as bonded warehousing for re-export rather than imports for domestic consumption.

Recovery of customs duty not levied or short-paid may proceed through a show-cause notice under Section 28 of the Customs Act, 1962 without prior appellate modification of self-assessment; the assessment-modification requirement applies to refund claims, not recovery. Anti-dumping duty imposed under Section 9A of the Customs Tariff Act, 1975 constitutes customs duty and is included in the aggregate value for IGST on imports, so corresponding duty, IGST and interest remain payable. A penalty for contravention must not exceed the statutory maximum in force on the date of import; a later enhanced ceiling cannot apply to earlier imports.

Imported used rails, sleepers, bails and G.I. angles fall under ferrous waste and scrap where their condition at import makes them unfit for original use and suitable only for melting or re-rolling; former identity does not control classification. Declared transaction value may be rejected only on reasonable doubt under Rule 12, followed by sequential valuation methods under Rule 3 with disclosed supporting material and an opportunity to rebut it. Exemption, differential duty, interest, confiscation and appropriation depend on valid classification and valuation. Redemption fine generally requires goods to be available, unless released on bond or undertaking. Customs penalties require proof of statutory ingredients, including person-specific culpable conduct.

Tariff reclassification requires Revenue to establish each proposed entry through disclosed, article-specific evidence applying the General Rules for Interpretation, relevant notes and Explanatory Notes. Generalised conclusions, undisclosed website material, reversal of the burden of proof and disregard of binding appellate precedent undermine a speaking classification determination. Absent proven reclassification, the declared classification and consequential concessional-notification benefit continue; accepted revised classification of other articles remains subject to limitation and quantification. Extended limitation requires pleaded and proved culpable conduct, while a corrigendum cannot introduce fresh charges retrospectively. Incorrect classification alone does not establish confiscation where description and value are undisputed, and unsupported duty demands cannot sustain redemption fine, penalty or interest.

MEIS benefit remains available where an exporter inadvertently marked the Reward declaration as "N" rather than "Y" in EDI shipping bills, provided the error is rectified. Section 149 of the Customs Act and Clauses 5 to 7 of Public Notice No. 30/2023 permit transmission of relevant shipping-bill records from the Customs backend to DGFT. A genuine exporter's substantive entitlement under a beneficial export-incentive scheme should not be defeated by a curable procedural or technological error. The EDI records must be corrected to "Y" and the amended shipping bills transmitted to DGFT to implement the MEIS benefit.

Review jurisdiction permits reconsideration only where an error apparent is established in the challenged order. Examination of the review petitions and supporting grounds disclosed no such error or basis for reconsideration. The review petitions were therefore dismissed, and pending applications were disposed of. Delay in filing was condoned, without affecting the rejection of review on merits.

Alleged unaccounted cash consideration on a property sale cannot be sustained solely on a third party's inconsistent statement and WhatsApp chats recovered from that third party, where the registered sale deed records consideration received through banking channels and no buyer inquiry, reconciliation, or independent evidence establishes cash payment. The rebuttable presumptions under Sections 132(4A) and 292C apply against the person from whose possession the material is found, not against a third-party assessee without corroboration. The addition for alleged cash consideration was deleted.

Delay in filing a first appeal may be condoned where the taxpayer diligently pursued rectification of a Section 143(1) intimation and pandemic-related limitation extensions applied. The disputed intimation assessed gross receipts without allowing claimed expenditure, despite timely filing of Form 10BB under Section 139(1). On these stated facts, sufficient cause supported restoration for merits adjudication, with necessary documents and an effective hearing.

Section 54F limits capital-gains relief where the taxpayer owns more than one residential house on transfer of the original asset. A shop-cum-office verified as commercial property is not counted as a residential house for that condition, leaving relief available subject to other statutory requirements. Section 54B permits relief for eligible investment in agricultural land. An urban location alone does not negate land's agricultural character where purchase deeds and verification establish that character; relief is available to the extent of documented eligible investment, with consequential recomputation of income and interest.

Section 50B prescribes a self-contained method for slump-sale capital gains, using the undertaking's net worth as acquisition cost and prescribed fair market value as consideration. Where Form 3CEA, the accountant's report and valuation comply with Rule 11UAE, net worth cannot be reduced to nil through extraneous adjustments. An addition exceeding the amount proposed in the show-cause notice conflicts with natural justice and CBDT Instruction No. 20/2015. The statutory computation of the slump-sale capital loss was therefore sustained.

Revision under Section 263 applies where an assessment order is erroneous and prejudicial to the interests of the revenue. Explanation 2(a) treats an order passed without enquiries or verification that should have been undertaken as meeting that condition. A cryptic, non-speaking assessment order that contains no factual particulars of enquiry into transactions, claimed expenses, or declared profit may fail to demonstrate the Assessing Officer's application of mind. Where the record does not establish such enquiry, revisionary jurisdiction is valid, particularly when the revisional authority has examined relevant financial details and submissions.

Purchase additions arising from supplier verification require fresh factual examination where the supplier later clarifies that sales from a unit were omitted and supports that clarification with invoices, payment records, GST material and delivery evidence. The assessee's earlier differing explanation must also be verified. A reasonable opportunity of hearing is required before deciding whether the disputed purchases are allowable. The purchase claim and supplier's clarification therefore require verification before any lawful addition is determined.

Section 80GGC deduction requires a genuine political contribution, not merely a donation receipt and payment through banking channels. Investigation material, un-retracted statements recorded under Section 132(4), bank-trail analysis and an established accommodation-entry arrangement involving layered funds can outweigh apparent documentation. Applying human probabilities and the preponderance-of-probabilities standard, the contribution described was treated as non-genuine and therefore ineligible for deduction under Section 80GGC.

Revenue expenditure classification applies to invoice-supported materials consumed regularly in business operations and to rates and taxes, where the accounts are accepted and no item is shown to be bogus, non-genuine or fictitious. Mere expenditure quantum or an unsupported assertion of enduring benefit does not establish a capital asset or justify capital treatment. In the absence of rejected books, identified evidentiary defects, or a demonstrated capital character, an ad hoc percentage disallowance is unsustainable. The expenditure is therefore treated as allowable revenue expenditure.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Explanation 2(a) covers a failure to conduct enquiries or verification that ought to have been made, not merely an allegedly inadequate enquiry. Examination of seized records, statements, supporting documents, digital data and third-party responses, together with summons and notices, demonstrated substantive verification. Where the Assessing Officer evaluates that material, makes additions and adopts a view, further investigation into the same material cannot replace an independent finding that the assessment is erroneous or legally unsustainable. The revision order was invalid and the assessment was restored.

Section 11 exemption cannot be denied solely because the audit report in Form 10B was filed separately from the income-tax return. Where both the return and audit report are filed within the prescribed statutory period and the report is available when the return is processed under Section 143(1), separate filing is a procedural lapse rather than a failure of substantive exemption conditions. The exemption remains available, and denial solely on that basis is set aside.

Section 151 requires sanction from the statutorily designated PCCIT before a Section 148 reassessment notice issued beyond the prescribed period; approval by a PCIT does not cure the jurisdictional defect. Cash-deposit additions under Section 69A made in ex parte reassessment proceedings require an effective opportunity for the assessee to address the disputed deposits. Where neither the assessment nor the first appeal afforded that opportunity, the addition requires de novo adjudication after a reasonable hearing.

Tax-deduction disallowance on interest does not arise where no interest is credited or paid in the relevant year; brought-forward closing balances alone do not trigger withholding. Section 69C applies only to unexplained expenditure incurred during the relevant financial year, so a recorded capital advance paid through banking channels in an earlier year cannot be treated as fresh unexplained expenditure merely because it remains in the balance sheet. Amounts already added back as capital write-offs cannot be added again. Notional interest is not taxable where no real income accrued, and project-interest disallowance fails where tax was deducted and deposited within the prescribed time. The additions and disallowances were deleted.

Section 68 does not permit cash deposits in specified bank notes during demonetisation to be treated as unexplained cash credits where recorded cash sales establish their source. Accepted trading results and stock records free from defects support the genuineness of the recorded sales; the absence of customer particulars for cash sales alone does not make the sale proceeds unexplained. On these facts, the addition for unexplained cash credit was deleted.

Penalty for misreporting of income under section 270A(9) does not arise merely because employees' PF/ESI contributions are disallowed on a technical basis. Where the taxpayer disclosed the payments and all related particulars in its records and tax audit report, and no material establishes suppression or misrepresentation of income, rejection of the claim does not constitute misreporting. The penalty was therefore unsustainable.