Assessed imported garments should not be detained or denied SAFTA preferential duty treatment on unsubstantiated allegations of intellectual-property-right infringement, defective Certificates of Origin, or misdeclaration. Origin certificates accepted at assessment, confirmation by the issuing authority, absence of brand-related evidence, and comparable imports cleared at declared values support release on the assessed Bills of Entry. Provisional-release valuation cannot rely solely on an unparticularised market enquiry without comparable transactions or reliable supporting material. Customs cargo service providers cannot charge rent or demurrage for goods seized or detained by the proper officer; unlawful detention requires waiver of consequential demurrage, detention, and related charges.

Refund of excess customs duty is available for crude soybean oil imported under the tariff rate quota scheme where bills of lading were dated on or before 31 March 2023 and the goods landed before 30 June 2023. The concessional tariff benefit applies to qualifying imports meeting those conditions, requiring refund of duty paid in excess in accordance with law.

Duty-free import benefits available to a 100% Export Oriented Unit permitted imported or domestically procured raw materials to be used for finished goods and for capital goods manufactured for use within the unit, subject to accounting and bonding requirements. Customs duty became payable only on clearance outside the unit, debonding, or exit from the scheme. The clarificatory circular applied retrospectively to the company without challenge; consequently, the seizure memoranda and show-cause notice were set aside, the bank guarantee was cancelled, and deposited amounts were refundable.

Unsecured loans supported by lender confirmations, income-tax records, audited financial statements and bank statements satisfy the initial burden of establishing the lenders' identity, creditworthiness and the genuineness of the transactions for Section 68 purposes. Repayment through banking channels with interest further supports transaction genuineness. Third-party material cannot justify an unexplained cash-credit addition unless it is specifically connected to the impugned loans and documentary evidence contains an identified defect or deficiency. On these facts, the loans were not treated as unexplained cash credits and deletion of the addition was sustained.

Statutory sanction under Section 151 must be communicated to and received by the Assessing Officer before issuance of a reassessment notice under Section 148. An undated approval endorsement, coupled with evidence that approval reached the Assessing Officer only after the notice was issued, establishes that the notice preceded effective sanction. This constitutes a fundamental jurisdictional defect, invalidating the reopening proceedings and consequential reassessment under Sections 143(3) and 147. A jurisdictional objection on this point may be raised where the relevant facts are already available on record.

Unsecured-loan additions are unsustainable where creditor confirmations, tax returns, bank statements and funding-source details establish the lenders' identity, transaction genuineness and creditworthiness. The evidentiary burden then shifts to the Assessing Officer; without independent inquiry or contrary material, an addition cannot rest on failure to establish the source of source, a requirement applicable only from Assessment Year 2023-24. Alleged on-money investment additions are likewise unsustainable where an earlier co-ordinate determination concerning the same developer-side transactions found no on-money and no contrary material justifies departure. Both additions were deleted.

Section 254(2) confines rectification to patent, manifest and self-evident errors apparent from the record, including an unadjudicated ground; it does not permit review, reappraisal, or merits-based reconsideration. Accordingly, the request to alter remand directions on AMP expenses and share-purchase transfer-pricing adjustments was declined because it sought reconsideration of issues already addressed. Section 254(1) permits remand for fresh adjudication. The omission to decide the claim for tax deducted at source credit was rectified, requiring verification and grant of eligible credit in accordance with law.

The first proviso to Section 149(1)(b) retains the pre-amendment limitation regime for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, the six-year period expired on 31 March 2022. The amended extended limitation period cannot operate retrospectively to revive a reassessment notice already barred under the earlier regime. Exclusions of time connected with Section 148A proceedings do not override the proviso's limitation restriction. Consequently, the notice issued on 7 April 2022 was time-barred, and the consequential reassessment order was quashed.

Additional evidence omitted because of a former tax consultant's failure and an ex parte first-appellate order may be considered in the interest of justice. Cash-payment disallowance requires verification of whether each voucher records payment to one person exceeding the prescribed daily threshold or aggregates payments to multiple labourers that individually remain within the permissible limit. The Assessing Officer must examine the underlying payment particulars rather than treat the voucher total as conclusive. Fresh adjudication may follow after admitting the evidence, with all contentions remaining open.

Related-party advertising expenditure under section 40A(2)(b) requires objective evidence that payment exceeds fair market value; reliable comparable rates shift the evidentiary burden to the Revenue, and the advertising disallowance cannot be sustained without contrary material. Programme production for broadcasting or telecasting falls within contractual work under section 194C rather than professional or technical services under section 194J where the underlying transactions are substantiated. Advertising revenue accrues when an enforceable right to receive arises, not merely on invoice issuance, requiring verification where services span later periods and preventing double taxation. Commission provisions require proof of accrued liability and services rendered, without duplicate disallowance of sums already disallowed for tax-deduction default.

Rectification under section 254(2) is confined to a patent, manifest and self-evident mistake apparent from the record. Previously considered seized material, related-party orders, alleged on-money receipts and precedents on income extrapolation cannot be re-examined merely because an assessee disputes their interpretation or asserts factual parity. The provision does not permit reappreciation of evidence, replacement of a possible view, reconsideration of factual findings or review of appeal merits. No mistake apparent from the record arose, so rectification was declined.

Reassessment beyond four years after a completed scrutiny assessment requires recorded reasons that independently establish tangible material indicating income escapement and the taxpayer's failure to make full and true disclosure of material facts. Reasons must stand alone and cannot be supplemented subsequently. Where the original assessment obtained shareholder identities, PANs, confirmations and banking details, alleged accommodation-entry information must reliably link the identified shareholder to the purported entry provider. Shareholders' non-compliance with summons does not cure deficient recorded reasons. Reopening lacked both tangible material and an identified disclosure failure, rendering the reassessment void ab initio.

Section 54 permits deduction for investment in a new residential house where construction is completed within the prescribed period after transfer of the original house; construction need not commence only after that transfer. Where the plot was acquired before transfer and registered in the spouse's name, its cost was not eligible on the stated facts. Separately ascertainable construction expenditure remained eligible despite exclusion of the land component. Deduction was therefore confined to the eligible construction cost, while the land cost was excluded and the remaining capital gain was taxable.

Identified commission receipts arising from disclosed business activity cannot be treated as unexplained cash credits merely because they were received in cash, absent material showing a separate undisclosed source; only income embedded in those receipts may be taxed. Cash introduced by a proprietor into a proprietary concern likewise cannot be characterised as unexplained where available business cash supports it, since the concern lacks a separate legal identity. Conversely, unreconciled personal expenditure exceeding recorded withdrawals is taxable as unexplained expenditure where the taxpayer provides no cogent explanation or evidence of an explained source. Accordingly, additions for business receipts and proprietor cash were deleted, while the personal-expenditure addition was sustained.

Stamp-duty-value addition under Section 56(2)(x) depends on whether, where an agreement date differs from the registration date, consideration was fixed under the prior agreement and paid through a prescribed non-cash mode on or before that date. Evidence of the agreement, payment timing and banking-channel payments requires verification to identify the applicable proviso and appropriate stamp duty value. No merits determination arises until those facts are verified.

Section 54F is a beneficial capital-gains exemption provision that calls for liberal interpretation. Its conditions do not require the cost of a new residential house to be funded exclusively from the sale proceeds of the original capital asset or solely through withdrawals from the capital gains account. Timely deposit of sale consideration in that account meets the statutory deposit requirement. Investment records and municipal tax assessment evidence may establish construction of the residential house within the prescribed three-year period, supporting entitlement to exemption where the remaining statutory conditions are met.

Leave-encashment received by a non-government employee qualifies for exemption under Section 10(10AA) within the enhanced limit prescribed by Notification No. 31/2023. The enhanced limit applies retrospectively, supported by the explanatory memorandum confirming that no person is adversely affected by retrospective application. Where the factual and legal position remains unchanged, exemption cannot be restricted to the former lower limit. Accordingly, the stated leave-encashment receipt falls within the enhanced exemption threshold.

Reasonable cause for delayed filing was established by the taxpayer's residence shift, overseas employment and non-receipt of hearing notices, warranting condonation and merits adjudication. Audited accounts, books, transaction bills, creditor confirmations and supporting statements substantiated the cash deposits and unsecured loans. An inspector's report not confronted to the taxpayer could not wholly displace that evidence under natural justice principles. The additions were consequently confined to an aggregate amount over returned income, with the remaining addition deleted and income to be recomputed.

Section 69 applies only where the assessee made an investment that was not recorded in its books and whose nature and source remained unexplained. Payments made before the assessee firm existed, and confirmed as payments by a predecessor firm, could not constitute the assessee's investment merely because it assumed the related project liability. Any unexplained cash source required examination in the predecessor firm's assessment. Cash-flow details, buyer particulars and bank entries were not displaced through enquiry, and suspicion could not substitute evidence. A bank payment subsequently returned to the payer did not establish a separate cash payment without corroboration. No unexplained investment arose, and the related addition, tax treatment and interest were deleted.

Cash-balance additions based solely on the difference between opening and closing cash are unsustainable where the opening balance is carried forward from audited accounts, the books remain unrejected, and no individual cash receipt or payment is identified as unexplained. Brought-forward cash is not a fresh credit or receipt of the relevant year unless material establishes that it did not exist or represents current-year income. In the absence of false or unverifiable cash-book entries, the cash-balance addition was deleted.