The first proviso to section 149(1)(b) preserves the reassessment limitation available under the pre-amendment regime for assessment years commencing on or before 1 April 2021. The fifth and sixth provisos regulate computation under the amended three-year or ten-year framework but cannot extend that preserved limitation. Consequently, a reassessment notice for assessment year 2015-16 issued after expiry of six years from the end of the relevant assessment year was time-barred, and the consequential reassessment order was invalidated.

Cash deposits claimed to arise from cash sales require documentary verification linking the sales to the specific deposits. Matching aggregate turnover with VAT returns and establishing a cash-sales business do not alone prove that nexus; cash books, sales and stock registers, and date-wise or period-wise reconciliation must establish cash availability and rule out circulation through multiple accounts. Verification of the claimed source was remitted to the Assessing Officer with reasonable opportunity. A reassessment notice allowing less than seven days in its stated response date remained valid where the order followed only after twelve days and no inability or attempt to respond was shown; the cross-objection failed.

Where a draft assessment order is issued within the prescribed period, final assessment timing pursuant to DRP directions follows the specific statutory limits rather than the general assessment limitation. Tax computation must give effect to allowed brought-forward losses and unabsorbed depreciation, subject to verification against duplicate relief. RPM is appropriate for unaltered goods resold to independent customers where reliable gross-profit data and functional comparability exist; operating profit or loss alone does not disqualify a trading comparable. The other method can combine justified NAV and DCF valuations, and a deemed international transaction does not establish associated-enterprise status for secondary adjustment, which requires the actual relationship.

Functional comparability under the CUP method requires comparison of functions performed, assets employed and risks assumed; third-party guarantee data must be disclosed for effective rebuttal. In the absence of reliable comparable uncontrolled transactions or a proper FAR analysis, the transfer-pricing adjustment for counter-guarantee support was deleted. Lending income could not be equally allocated where the overseas entity funded loans and assumed substantive lending risks, and no reliable comparable or prescribed method disproved the attribution. An arm's length price cannot be determined ad hoc after rejecting TNMM without a comparable or prescribed method. Regional support expenditure was supported by evidence of services, business n.....

Unsecured loans alleged to be accommodation entries require evaluation of lender identity, creditworthiness and transaction genuineness. Confirmations, bank statements, ledger accounts, receipt through banking channels, and repayment with interest support those requirements; generic third-party search information or allegations of entry providers do not, without contrary material, displace such evidence. Interest expenditure connected with a supported loan requires evidence of actual incurrence or payment, rather than presumption or estimation based merely on an alleged consequential liability.

Comparable uncontrolled price method requires an actual uncontrolled transaction adjusted for material differences; bank lending rates with notional risk premiums and controlled related-party loans cannot serve as comparables. Same-year uncontrolled borrowings supported deletion of the transfer-pricing adjustment. Where interest-free own funds exceed investments, mixed-fund investments are presumed funded from own funds unless rebutted, deleting the Rule 8D interest disallowance. Administrative expenditure disallowance relating to exempt agricultural income was sustained because the assessing authority recorded dissatisfaction and the amount remained within exempt income. Interest on advances may be disallowed only upon proof that borrowed funds were diverted; absent that nexus, the interest disallowance was deleted.

Penalty under section 271D was time-barred because section 275(1)(c) required the penalty order to be passed within six months from the end of the month in which the penalty notice was issued. The notice was issued in January 2021, making July 2021 the statutory deadline; the March 2022 order fell outside that period. The penalty order was therefore invalid and quashed, and the appellate order was set aside.

Service of a valid reassessment notice is a jurisdictional condition precedent to reopening an assessment. The Assessing Officer bears the burden of proving actual service; absence of a valid postal receipt or other reliable proof leaves the jurisdictional requirement unsatisfied. Filing a return and participating in proceedings following an inquiry notice cannot cure non-service through consent, waiver or estoppel. Non-service is an incurable jurisdictional defect, rendering the reassessment proceedings and consequential assessment void ab initio.

Reassessment initiated on Insight portal and Investigation Wing information remained valid where the first appellate authority had rejected the objection and no infirmity was found in that determination. For purchases recorded through fictitious invoices, where materials were procured from another source, only the inflated profit component may be disallowed rather than the full purchase value. An estimated addition of 25% of the impugned purchases was sustained, and the appeal failed.

Notice under section 143(2) is a mandatory jurisdictional condition for completing a section 153C assessment that departs from a return filed in response to the statutory notice. Complete non-issuance is not a procedural irregularity capable of cure through section 292BB. Applying the view favourable to assessees amid divergent non-jurisdictional decisions, assessments completed under section 153C read with section 143(3) without such notice were quashed. Challenges to additions and other merits remained unadjudicated.

Search-assessment jurisdiction is confined to the statutory ten-year block computed from the search assessment year; assessments outside that period lack jurisdiction. Extension beyond six years requires escaped income represented by an asset: foreign travel expenditure and unsecured loans, being expenditure and liabilities respectively, do not meet that condition. In unabated years, additions must rest on incriminating material found during the search; disclosed transactions, recorded claims, prior-search statements, and material not proving the assessee's payment cannot sustain additions. Search assessments must also be completed within twelve months from the end of the financial year in which the last search authorisation was executed; completion thereafter is time-barred.

Royalty benchmarking for technical know-how requires reliable comparable uncontrolled transactions before applying the Comparable Uncontrolled Price method. Where royalty payments are interrelated with manufacturing and other international transactions, and no evidence establishes an independent royalty transaction or supports CUP comparables, entity-level aggregation under the Transactional Net Margin Method is appropriate; a benefit test alone cannot justify a nil arm's length price. Consistency also requires Revenue to follow an earlier transfer-pricing determination where the royalty agreement, rates, and material facts remain unchanged. The transfer-pricing adjustment on royalty payments was deleted and the Revenue's appeals were dismissed.

Contingency expenses reflected in CTC reports could not be disallowed where they matched the regular books, the books were not rejected, and no evidence showed inflation or fictitious claims; deletion was sustained under the rule of consistency. No disallowance of expenditure relating to exempt income was sustainable because no income exempt under Chapter III was earned; deletion under section 14A read with Rule 8D was sustained. The royalty transfer-pricing adjustment was unsustainable because no prescribed method or proper benchmarking had been applied and relevant joint-venture and support-service documents were not properly considered; deletion was sustained. The Revenue's appeal was dismissed, while the cross-objection was infructuous.

Year-end provisions for audit fees and contractor payments remain deductible where consistently accrued, discharged subsequently, and excess provisions are reversed and offered to tax. Unclaimed interest or capital expenditure recorded in the balance sheet cannot be added merely because it appears as an accrued liability. Section 251 permits remand or setting aside only for ex parte assessments under section 144, making remand for fresh verification impermissible for assessments under section 143(3). No disallowance arises for payments not subject to tax deduction at source or for expenditure relating to exempt income where no exempt income is earned. Income already offered to tax cannot be taxed again; actuarially valued leave-encashment liabilities are deductible; and under-reporting penalty requires valid initiation with recorded satisfaction.

Government departments remain equally bound by limitation requirements in Customs Act appeals. Vague assertions that earlier counsel caused delay do not establish sufficient cause where the department cannot explain file transfer, follow-up, retrieval, or inconsistencies over documents allegedly supplied. Administrative inaction, lethargic internal functioning, and an unsubstantiated effort to attribute delay wholly to counsel cannot justify condonation. In the absence of a reasonable explanation, the delay-condonation application was dismissed and the Customs Act appeal stood disposed of.

Revocation of a Customs Broker licence and forfeiture of security were disproportionate where the broker failed to verify authorisation and KYC documents, but the attempted prohibited export was actively undertaken by its employee and another person. Prompt action against the employee, absence of deliberate or intentional conduct by the broker, and no repeated violations supported retention of the licence with a penalty. Precedents involving repeated breaches and continuous licence misuse did not apply. The High Court upheld the Tribunal's proportionality finding, concluding that no substantial question of law arose.

Multifunctional car radio units designed for vehicle installation, with radio reception and sound-reproduction functions, fall under CTI 8527 21 00 where infotainment features such as touchscreen, Bluetooth, Wi-Fi, USB, camera input, playback and navigation remain supplementary. The absence of in-built speakers does not change that character. Under GRI 2(a), SKD kits comprising components configured solely for assembly into complete units may be classified as the finished unit when, as presented, they possess its essential character; assembly must be limited to minor operations without substantial transformation. Classification remains subject to consignment-level Customs verification and applicable BIS certification.

Section 212(1)(c) requires a demonstrable and reasoned formation of opinion based on cogent, relevant circumstances before an investigation is assigned to SFIO. The statutory order itself must disclose the material considered and the basis for both the investigation and its assignment; later committee minutes, affidavits, or investigation material cannot cure a deficient order. A prior dismissal of a co-accused's petition as premature, with liberty to pursue remedies later, does not create res judicata or bar scrutiny of the initiating action. The SFIO investigation order and consequential proceedings, including the prosecution complaint, were quashed.

Share-purchase consideration paid under a tripartite memorandum, without an obligation to repay or a return for its use, does not satisfy the requirement of disbursement against consideration for time value of money and therefore is not financial debt under the Insolvency and Bankruptcy Code. A claimed oral conversion into an interest-bearing loan requires proof and cannot be established in summary proceedings. Balance-sheet entries, balance confirmations, interest credits and tax deduction at source do not alter the payment's original character or independently prove such an agreement, especially where interest was not paid. Clerical misdescriptions causing no prejudice do not justify interference. Civil remedies remain open.

Insolvency admission for operational debt requires only a summary assessment of whether a plausible, genuine dispute existed before the demand notice; it does not permit a trial of the defence. A returned consignment, contemporaneous WhatsApp communications and a timely demand-notice reply may establish a pre-existing quality dispute. Questions over contractual quality terms, delivery arrangements, laboratory evidence and communication authority require determination in appropriate proceedings rather than summary insolvency adjudication.