Consumer-side electricity rates actually paid by cement units to independent distribution companies constituted valid internal comparable uncontrolled prices for captive power transfers under the specified domestic transaction regime. The arm's-length-price framework does not require exclusive use of generator-to-distribution-company rates; comparability under section 92C and Rule 10B remains transaction-specific. Although captive generators and distribution licensees have functional differences, those differences do not preclude comparison unless they materially affect it. Generator-side procurement rates were unsuitable because they reflected a different supply-chain stage, were not available to consuming units, and lacked comparability adjustments. The transfer-pricing adjustments were therefore deleted and that deletion sustained.

Peak-credit computation for merged undisclosed bank accounts must neutralise same-day transfers between those accounts, since they merely shift the same funds and cannot increase the highest adjusted balance. The resulting addition requires recomputation after excluding transfer effects, rather than calculating the peak from balances distorted by internal deposits. An undisclosed rental-income addition previously deleted in the first appellate round cannot be revived by the Assessing Officer during a set-aside assessment; it remains deleted. Quantification disputes are substantive appellate matters, not apparent errors capable of rectification, rendering a related rectification proceeding consequential.

Section 270A distinguishes ordinary under-reporting from under-reporting resulting from misreporting; a notice expressly alleging the latter need not identify a further sub-category. Claiming the full SEZ export-profit deduction where only half is eligible, coupled with inconsistent Forms 56F and correction only after scrutiny, can negate a bona fide explanation and constitute misreporting. Under-reporting under normal provisions is assessed by comparing assessed income with income processed on the return, so unchanged deemed income under section 115JC does not eliminate penalty exposure. Processing under section 143(1)(a) remains mandatory under the amended regime despite a scrutiny notice. Penalty may apply despite no revenue loss or demonstrated intent to evade tax, with required faceless approval.

Cash loans accepted from a spouse may attract penalty where the taxpayer cannot establish reasonable cause for using cash despite available banking channels. A family arrangement did not justify the cash acceptance because each taxpayer remains independently liable under the Income-tax Act. Subsequent repayment through cheque did not cure the contravention, which occurs when the loan or deposit is accepted in cash. The penalty was sustained and the appeal was dismissed.

Statutory presumption of smuggling for seized gold arises only on a reasonable belief supported by material rationally connected to smuggling; suspicion, absent documents, and domestic courier transport alone do not suffice. Inconclusive foreign origin, lack of foreign markings, an explanation of domestic melting, and unverified recipient or laboratory details may prevent the presumption from operating. Confiscation requires proof of illegal importation or a lawfully raised presumption; recovery at an airport cargo complex does not itself meet the requirements for concealment in imported packages or unauthorised removal from a customs area. Penal liability also requires a specific act or omission and knowledge or reason to believe that the gold was smuggled.

Statutory exclusion of appellate jurisdiction over orders concerning goods imported as passenger baggage applies to gold carried into India by an international passenger. Gold retains its character as passenger baggage even when recovered from clothing rather than luggage. Concealment or non-declaration may affect confiscation and penalty, but cannot create appellate jurisdiction where the subject matter is statutorily excluded. Challenges concerning confiscation and penalty for such gold must proceed through the statutory revisional remedy rather than appellate proceedings before the Tribunal, with merits remaining open.

Customs Broker due diligence does not require anticipating a later departmental classification view where the broker acts on available documents, cannot ordinarily inspect goods, and lacks knowledge or connivance in a misdeclaration. Classification forms part of the importer's self-assessment, and an incorrect classification may be addressed through reassessment or other remedies under the Customs Act. Where competing tariff entries for boiled betelnuts were plausible, classification as supari rather than arecanuts did not itself establish breaches of Customs Broker obligations. Licence revocation, security-deposit forfeiture and penalty were set aside, with immediate ICEGATE filing access directed.

Accurate disclosure of imported goods by description, part number, value and origin means that a disputed tariff classification alone does not constitute misdeclaration for confiscation; confiscation and redemption fine cannot stand, particularly without market-price determination. Before express statutory incorporation, interest, penalty and confiscation provisions did not apply to the IGST component of customs duty. SEZ legislation charging duty on removals to the Domestic Tariff Area did not itself provide recovery machinery for short-paid duty or import Customs Act recovery provisions. Extended limitation requires wilful misstatement or suppression with intent to evade duty; a bona fide interpretative classification dispute confines recovery to the normal period and defeats the related penalty.

Section 4 of the Income-tax Act, 2025 charges income-tax on each person's total income for the tax year at rates enacted by a Central Act and includes additional income-tax. It also provides for tax deduction at source, tax collection at source, and advance tax. The comparable 1961 provision uses the assessment-year and previous-year framework and does not expressly mention tax collection at source. Neither charging provision specifically refers to self-assessment tax or direct payment, which are separately addressed under other provisions, raising a question concerning their levy and collection.

Additional grounds of appeal under Section 107(10) and additional evidence under Rule 112 are distinct mechanisms. A new ground does not automatically permit fresh evidence, and admission of evidence does not validate an inadmissible ground. Rule 112 permits evidence only in specified circumstances, requires written reasons for admission, and protects the opposing side through an opportunity to examine, cross-examine, or rebut the material. Departmental material introduced at the appellate stage cannot prejudice a taxpayer without consideration of objections and a meaningful opportunity to respond.

Condonation of delay in income-tax appeals requires a demonstrated and genuine explanation, not an afterthought. Professional advice may explain delay where it is proven and not attributable to negligent or casual conduct. The assessee bears the onus of establishing sufficient and plausible cause. Tax authorities must act according to law, avoid technical objections that deny lawful rights, and ensure that only legitimate tax is collected. Explanations based on later professional advice and unagitated additional grounds require close scrutiny.

Sections 153 and 154 revise post-supply discount treatment by removing the former requirement of a pre-existing agreement and invoice-specific linkage. Exclusion of the discount from taxable value requires a credit note under Section 34, reversal by the recipient of attributable input tax credit, and compliance with applicable credit-note requirements. Section 155 extends provisional refunds of up to 90% to eligible inverted duty structure claims, subject to prescribed conditions, safeguards and final verification. It also removes the minimum refund threshold only for tax paid on goods exported out of India, while retaining it for other refund categories.

Recipient-generated e-invoicing is proposed for specified reverse-charge transactions involving domestic procurements from unregistered suppliers and imported services. Eligible taxpayers may need to issue self-invoices and obtain Invoice Reference Numbers through RCMDOM and RCMIMP reporting. The applicable time-of-supply and self-invoice rules may require e-invoice generation within 30 days of service receipt. Delays may create interest exposure and input tax credit concerns, requiring coordinated procurement, finance, accounts-payable and ERP controls.

Section 109(8) of the CGST Act requires both satisfaction of the monetary conditions and absence of a question of law for Single Member hearing. Disputes concerning documents required for goods movement, liability for detention proceedings, the legal effect of missing invoices, penalty consequences, and the applicability of CBIC Circular No. 64/38/2018-GST require interpretation of Sections 68 and 129 read with Rule 138. Such issues are not resolved merely by factual verification and require a Bench comprising one Judicial Member and one Technical Member.

Approval of a resolution plan under the Insolvency and Bankruptcy Code binds the corporate debtor, creditors, and governmental authorities regarding statutory dues. Central excise demands arising before plan approval that are not included in the approved plan are extinguished. Recovery proceedings for those excluded pre-approval dues cannot continue, so the demand ceases to be enforceable against the corporate debtor.

General insurance services used in relation to manufacturing remain eligible as input services for CENVAT credit after the amended definition narrowed the scope of eligible services. Although the phrase "activities relating to business" was removed, insurance retaining a direct or indirect nexus with manufacture falls within the principal limb of the definition. Credit is not barred unless the service falls within specified exclusions, including certain construction, motor-vehicle, or employee personal-use services. Clarification concerning sales commission does not restrict credit for otherwise qualifying insurance services.

Extended limitation for service-tax short-payment under the proviso to Section 73(1) requires proof of fraud, collusion, wilful misstatement, suppression of facts, or contravention intended to evade tax. Regular ST-3 filings and tax payment based on an understanding of works contract and reverse-charge treatment do not, without such proof, establish grounds for invoking the extended period merely because taxable value or self-assessment is considered incorrect. Section 72 best-judgment assessment addresses dissatisfaction with accounts but does not replace those limitation conditions. The demand was time-barred, and penalties were unsustainable.

Section 85(3A) of the Finance Act, 1994 requires appeals to the Commissioner (Appeals) to be filed within two months, with delay condonable on sufficient cause only for a further month. An appeal filed more than twelve months after receipt of the adjudication order falls outside this aggregate three-month period. The statutory limitation restricts the Commissioner (Appeals)' power to condone delay, and neither the Tribunal's appellate jurisdiction nor general appellate provisions can override that express limit. Such an appeal is barred by limitation and cannot be entertained or condoned.

Commission-based marketing and order-procurement services supplied to foreign principals qualify as exports where the foreign principal engages the Indian provider, pays the commission in convertible foreign exchange, and uses the services for its own business. Under the place-of-provision rules, the recipient is the person whose instructions are acted on, business need is met, and consideration is borne; Indian customers affected by the performance are not recipients merely because they place orders. The service destination is determined by consumption, not performance location. Extended limitation cannot apply where service-tax returns disclosed the export activity and no positive evidence establishes wilful suppression or intent to evade tax.

Tariff-classification differences, where Bills of Entry accurately disclose the goods and material particulars, do not by themselves constitute misdeclaration supporting confiscation or redemption fine. For the relevant period, IGST imports lacked a statutory basis for interest or penalties; the later extension of those consequences applied prospectively. Goods removed from a Special Economic Zone to the Domestic Tariff Area were chargeable, but no recovery machinery supported the identified short-levy and consequential punitive demands. Extended limitation and related penalties require collusion, wilful misstatement or suppression with intent to evade duty; absent those elements, liability is confined to the normal period, with interest only on basic customs duty and social welfare surcharge. Quantification and consequential adjustments require remand.