Functional comparability in transfer pricing is a factual, data-driven assessment that must conform to Rule 10B. The High Court upheld the exclusion of an outsourced-service provider from the comparable set because outsourcing a major portion of its work made it functionally dissimilar to the assessee. The Revenue produced no contrary material and failed to establish perversity, reliance on irrelevant material, or exclusion of relevant material in the Tribunal's factual finding. The substantial questions of law were answered for the assessee, and the Revenue's appeal was dismissed.

Limited Scrutiny confines the Assessing Officer's enquiry to the CASS issue notified to the assessee unless prescribed safeguards permit examination of an additional issue. A deduction for donations for scientific research and expenditure on an assessee's own in-house R&D facility are distinct statutory claims, notwithstanding their connection with section 35. The notified donation issue could not be expanded to review the in-house R&D deduction without credible specific information, recorded reasons, prior approval and required intimation. Participation in proceedings, a questionnaire, Form No. 3CL, or curative provisions could not create jurisdiction. The resulting disallowance under section 35(2AB) was deleted.

Reassessment is not a change of opinion where original scrutiny records contained relevant material but the agricultural-land reinvestment claim and actual sales commission were never examined. Agricultural-land reinvestment may qualify for deduction where an agreement to sell provides for instalment consideration and proportionate possession, and replacement land is acquired from consideration received before execution of the final sale deed. A differential commission addition is unwarranted where Form 26AS and the profit and loss account reconcile the actual commission received, including its treatment through evaporation loss.

Penalty for unexplained fixed-deposit credits is not warranted merely because an addition is sustained under the deeming provision for unexplained credits when deposits were accepted under a public fixed-deposit scheme. Depositor particulars, supporting records, and an explanation that certain deposits were renewals supported the bona fides of the explanation. Without independent material establishing that the deposits represented undisclosed income, the addition alone did not justify concealment penalty. The penalty was deleted, while remaining grounds were left open as academic.

For interest on excess refund, a reassessment is a regular assessment only if it is the first assessment in the case. Where reassessment follows a scrutiny assessment, it does not meet that condition. Interest under section 234D therefore cannot be levied on an excess refund in those circumstances, and the charge is deleted.

Section 80GGC deduction depends on proving that a payment to a political party was a genuine contribution. Payment through banking channels and the recipient's registration are relevant but not conclusive. Genuineness may be assessed through the test of human probabilities, including evidence that the donee issued false receipts or returned donations, inconsistencies in the claim, incomplete bank records, failure to provide requested information, and non-response to enquiries. On such cumulative material, a deduction may be disallowed without relying solely on third-party statements. A challenge limited to the initiation of penalty proceedings is premature.

Misreporting penalties for under-reporting require identification of a specific statutory form of misreporting and evidence of its factual nexus with the assessee. Withdrawal of a political-party donation deduction after a reassessment notice, without more, does not establish misreporting. A political party's alleged general modus operandi is insufficient without material linking the assessee to the arrangement, return of the donation in cash, or knowing participation in an accommodation-entry transaction. On these facts, the enhanced penalty for misreporting was deleted.

The safe-harbour tolerance-band proviso to section 56(2)(x)(b) addresses unintended hardship where purchase consideration and stamp-duty value differ only marginally. Its remedial and clarificatory character supports application from the provision's original operation, including Assessment Year 2018-19, rather than only prospectively. As the proviso is pari materia with related stamp-duty valuation provisions, a variation within the statutory tolerance margin does not sustain a deeming addition. The marginal valuation difference therefore did not justify addition as deemed income.

Quality Control Order exemption for steel imports turns on the Bill of Lading showing shipment by the stipulated date. The Steel Import Monitoring System requires an Automatic Registration Number application within its prescribed pre-arrival registration window, but does not require ARN generation before the QCO exemption cut-off. Imposing that additional requirement is inconsistent with the stated conditions; imports meeting the shipment condition and timely ARN application qualify for exemption. Valid exemption notifications create accrued, vested rights after conditions are fulfilled and cannot be withdrawn retrospectively unless authorised by statute. The refusal to enable ARN generation was quashed.

Timely payment under section 28(6)(i) statutorily concludes all matters stated in a customs show-cause notice, except proceedings expressly preserved. On that reading, proceedings concerning provisionally released imported goods cannot continue selectively for confiscation, redemption fine or penalty under section 114A after statutory conclusion. Redemption fine requires a valid confiscation order, while the proviso to section 125 regulates an existing confiscation power and cannot revive a power already brought to an end. Precedent concerning provisionally released goods does not determine the consequence of statutory conclusion under section 28(6)(i).

Confiscation in rem may validly apply to foreign-origin goods concealed in an import consignment that remain uncleared for home consumption, regardless of whether the named consignee qualifies as an importer. Personal penalties under sections 112(a) and 114AA require evidence that the consignee or partner ordered the goods, committed or abetted the offending act, or knowingly used a false declaration. Naming in a bill of lading alone does not establish importer status or knowledge. Untested witness statements and electronic correspondence lacking statutory proof cannot sustain penalties; confiscation remained valid while penalties were set aside.

Electric steering lock assemblies functioning solely as anti-theft immobilisers, rather than components transmitting or participating in steering movement, fall under CTH 8708 9900 as other motor-vehicle parts and accessories, not CTH 8708 9400. Reclassification requires cogent technical evidence, and AIS-075, HSN Explanatory Notes, or an earlier incorrect declaration cannot expand the narrower steering-system entry. Where goods are fully described and the dispute is a bona fide interpretative classification issue, no misdeclaration supports confiscation, no extended limitation applies absent fraud, suppression or wilful misstatement, and no penalty arises without culpable conduct. Redemption fine is unavailable where goods were already cleared for home consumption.

Alternative tariff classification raised in customs adjudication must be examined on merits, even if it falls outside the show-cause notice, because duty must be correctly assessed according to law. The alternative classification and related exemption claims were remanded for fresh adjudication for the normal period. Redemption fine cannot be imposed where goods cleared for home consumption are unavailable for confiscation, and the fine was set aside. Penalty under section 112 does not arise from a bona fide interpretational classification or exemption claim without misdeclaration, suppression, or deliberate duty-evasion conduct; the penalty was therefore set aside.

Co-accused statements and WhatsApp-chat material cannot support customs penalties where the statements lack independent corroboration, the makers are not cross-examined, and electronic data from a seized phone is not reliable or cogent. Penalties for assisting import of concealed prohibited or misdeclared goods require proof that the person knowingly abetted conduct rendering goods liable to confiscation. Penalties for false declarations additionally require knowing or intentional use of materially false documents. Without proof of knowledge, deliberate conduct, or false declaration, the penalties were set aside.

Duplicate customs duty payments compelled by a payment-portal error after the original duty liability is discharged constitute unauthorised excess collection, not customs duty. Accordingly, the statutory limitation for customs-duty refund claims does not govern recovery of the duplicate payment. A precedent involving valid tax payment followed by exemption is inapplicable. Setting aside the refund rejection permits the refund, while the connected recovery demand for an already sanctioned refund becomes infructuous.

Conditional exemption for parts used in solar photovoltaic modules is confined to parts consumed within the factory where those parts are produced. Imported or externally procured aluminium profiles remain outside the exemption even if fabricated elsewhere and ultimately used in module manufacture. Extended limitation for recovery of differential customs duty requires wilful misstatement or suppression of material facts; merely claiming a classification or exemption in a Bill of Entry does not establish suppression. Prior audits and earlier proceedings may also negate an allegation that material facts were withheld. Consequential interest and penalties depend on a sustainable, timely duty demand.

IGST exemption for aircraft parts re-imported after overseas repairs remains available under the re-import exemption framework. The later insertion of the words "tax and cess" and Explanation (d), used to support an IGST levy, was treated as ultra vires following its invalidation by the High Court. The associated circular cannot independently sustain IGST on repaired parts re-imported from abroad. Customs-duty exemption provisions therefore do not authorise IGST on eligible re-imported aircraft parts.

Motherboards imported without processors and RAM for assembly into an industrial computing platform are classified as parts of automatic data processing machines under Tariff Item 8473 30 20. Model-specific chassis designed solely or principally to house that platform's components are likewise classified as machine parts under Tariff Item 8473 30 99. AC-to-DC power supply units perform rectification and are independently classifiable as static converters under Tariff Item 8504 40 29, rather than as machine parts, because of their specific coverage in Chapter 85. Static converters designed for an automatic data processing machine may receive the applicable customs-duty exemption, subject to notification conditions, BIS certification, and import verification.

Regulation 38(3)(a) requires a resolution plan to identify and address the cause of default; merely describing losses, lack of turnover and excess liabilities does not satisfy that mandatory requirement. Non-compliance also breaches the statutory plan-scrutiny requirement and can justify rejection despite CoC approval. Protection for dissenting financial creditors extends to their minimum liquidation entitlement, not to a requirement that total plan value equal liquidation value. Investigation into the corporate debtor's affairs may be sustained where debt assignments during CIRP, voting control and plan deficiencies warrant inquiry. Premature limits on an assignee's distributable share should be removed pending investigation. Rectification or CIRP restoration before liquidation remains discretionary where defects are substantive rather than minor.

Section 44(1)(c) of the PMLA establishes a committal process for moving a scheduled-offence proceeding to the Special Court dealing with the associated money-laundering complaint when cognizance has been taken by different courts. An authorised PMLA authority cannot exercise its discretion in a manner that defeats this statutory scheme, while the court trying the scheduled offence retains responsibility for deciding the committal application. Under Article 226, a direction to initiate the committal process concerns an authority subject to writ jurisdiction rather than a judicial transfer of criminal proceedings. A sufficient territorial nexus may support such a direction even where the scheduled-offence proceeding is pending outside the State.