TCS under section 52 applies to the Tea Board as an electronic commerce operator conducting electronic tea auctions and settling payments. Buyers deposit a consolidated amount in an escrow account covering tea value, brokerages and Tea Board charges. TCS is collected separately from tea producers on the net value of tea supplies and from auctioneers on the net value of brokerage services. Auctioneers do not receive payment for tea sold through auction.

Stamp-duty valuation differences within the 10% tolerance applicable under the seller-side valuation rule cannot support a purchaser-side addition for inadequate consideration under Section 56(2)(vii)(b)(ii). The beneficial tolerance therefore prevents deemed-income treatment where the variation remains within that range. Limited-scrutiny assessments are confined to issues identified in the scrutiny notice. An addition concerning an issue outside that scope is without jurisdiction unless the assessment is validly converted to complete scrutiny through the required approval process. Both additions were consequently removed from the assessed income.

Del-credere agent status under Para 3 of Schedule I depends on invoicing. Where the supplier invoices the customer, including through the DCA, the DCA is not an agent and its buyer loan is an independent principal-to-principal service; related interest is excluded from the value of goods supplied by the principal. Where the DCA invoices in its own name, it is an agent. Credit extended by such DCA is subsumed in its supply of goods, and the related interest is included in the value of that supply.

Time-expired drugs or medicines may be returned either as a fresh supply or through a credit note. Registered persons may invoice a fresh return supply, while composition taxpayers issue a bill of supply and unregistered persons may use a commercial document without tax. Input tax credit on a fresh return supply must be reversed if the returned goods are destroyed. Under the credit-note method, tax liability may be adjusted only where the statutory timing and input tax credit conditions are met; otherwise, the credit note may be issued without tax adjustment or portal declaration.

A casual taxable person must deposit advance tax on estimated net tax liability after allowing due eligible input tax credit. Exhibitions operating beyond 180 days require normal taxable person registration, supported by an allotment or consent letter for the premises; no advance-tax deposit is required and registration may be surrendered after the exhibition. Excess input tax credit improperly distributed by an Input Service Distributor is recoverable from recipient units with applicable interest and penalty, with voluntary payment through FORM GST DRC-03 or recovery proceedings where payment is not made.

Cash found during a search remains unexplained money where the assessee attributes it to relatives but they cannot substantiate its source. Claims by the mother and wife required independent support, such as bank withdrawals, disclosed earnings, or other cogent material. Confirmations and affidavits alone did not establish ownership or the source of the cash. The addition for unexplained money was therefore sustained against the assessee.

Domestic containers may move by rail or road between CONCOR-operated inland facilities and port terminals only under segregated handling, pre-advice, Customs approval, seal verification, and designated storage requirements. Containers must be distinctly identifiable from EXIM containers and secured with CONCOR seals. Tampered seals bar terminal entry; if detected within the terminal, cargo requires 100% Customs examination at a CFS under Customs supervision at CONCOR's cost. Outbound rail rakes must keep domestic and EXIM cargo separate, contain at least 50% EXIM cargo, and prioritise EXIM loading. Weekly reconciliation reports and indemnity bonds are required.

DPD importers are encouraged to submit a one-time default intimation, preferably electronically, to avoid repeated consignment-wise advance intimation to shipping lines. The mechanism facilitates direct clearance and is intended to reduce transaction time and cost. Failure to notify shipping lines in advance may lead to container movement to container freight stations and consequent delays and additional costs. Non-compliance by shipping lines after acceptance and publication of the intimation should be reported to the DPD Cell.

Rectification of an apparent error may require limited recall where the record does not clarify whether depreciation on goodwill arising from amalgamation was allowed in the preceding year and cited judicial decisions were not considered. The earlier appellate order was recalled only to examine and verify the depreciation-on-goodwill claim on the written-down value of intangible assets, with rehearing confined to that issue.

Exporters using RFID seals for self-sealed export containers must declare the seal type in the designated shipping-bill field at filing. This declaration is necessary to obtain the full benefit of the risk management system and addresses omissions in recording seal details. The requirement forms part of the self-sealing framework for export containers and operates as a standing instruction for customs officers and staff.

Non-adjudication of a ground challenging partial disallowance of business expenses, despite its inclusion in Form No. 36, constitutes a mistake apparent from the record. A discrepancy between the serial numbering in Form No. 36 and separately annexed grounds does not negate that the ground was duly raised. Rectification is therefore available through limited recall confined to adjudicating the omitted ground.

Revision under section 263 was sustained for verification of depreciation on goodwill and revalued intangible assets arising from amalgamation, including consequential written-down-value and brought-forward-loss claims, because the assessment record did not evidence examination or findings despite general depreciation details having been furnished. Revision failed for prior-period rent because it had already been voluntarily disallowed, causing no revenue prejudice, and for the amalgamating entity's disclosed income and expenditure because revised filings showed no assessment error. Depreciation on furniture and fittings for AY 2014-15 must be determined using the revised tax audit report and reconciled written-down value; the revised report cannot be disregarded.

Before granting Out-of-Charge for imports of cosmetics, drugs and medical devices through Partner Government Agency-facilitated Bills of Entry, the proper officer must verify applicable licences, permissions, registration certificates and prescribed particulars against the relevant checklist. Importers, Customs Brokers and other stakeholders must upload mandatory compliance documents through e-SANCHIT to enable verification and expedited clearance.

Where imported goods held for investigation, examination or testing are unlikely to be cleared more than 10 days after examination, the CFS custodian must issue written or email advice on the Section 49 storage facility and send a reminder after 20 days. For CFS open-examination consignments delayed beyond five days because of sample testing, PQ/AQ/FSSAI NOCs or discrepancies, the Shed DC/AC must similarly notify the importer or authorised Customs Broker, with a reminder 10 days after sample drawal. Custodians and service providers must maintain communications and records.

Agricultural-land exemption claims require factual verification where newly obtained official material concerns horticultural use and the land's character; taxability therefore remains for fresh adjudication. Consideration described as compensation on cancellation of a real-estate joint venture is revenue/business income where stock-in-trade land and development rights are conveyed, with no separate right or income-producing apparatus lost. The same income cannot be taxed on both accrual and receipt, requiring verification of prior inclusion. Housing-project deduction eligibility depends on whether buildings form one project and on applicable approvals. Unsupported ad hoc expense disallowance lacks an evidentiary basis, whereas proportionate motor-car expense and depreciation restriction can apply where exclusive business use is unproved.

Interest earned by a co-operative housing society on investments or deposits with co-operative banks qualifies for full deduction under Section 80P(2)(d) where those banks remain co-operative societies registered under applicable State law. A co-operative bank's RBI licence and banking activities do not alter its status as a co-operative society for this purpose. Since the interest arose from specified co-operative banks rather than nationalised banks, it falls under the separate deduction for income from investments with co-operative societies, not the provision concerning profits from banking or credit-facility business. The disallowance was reversed in favour of the assessee.

Expert Panel Valuers may be empanelled for import-export valuation of diamonds, jewellery, gemstones, pearls and other valuable articles. Selection involves scrutiny of qualifications and experience, practical assessment and interview. Applicants must establish relevant valuation competence, submit supporting records and references, maintain a clean professional record, and act independently without conflicts of interest. Appointed valuers must provide standardised reports, preserve relevant records, cooperate with proceedings, and render services voluntarily without remuneration. Appointments are non-transferable and remain subject to performance review, suspension, cancellation or removal for false valuation, negligence or professional misconduct.

Manual Container Movement Permission is discontinued in Mangaluru Customs Commissionerate for duty-free container imports. Manual Continuity Bonds must be recorded in ICES through a National Bond Number, enabling electronic debits and credits from manifest messages. Until full automation, quarterly Annexure A and B reports on bond balances, container imports, re-exports, pending containers and extensions remain mandatory. Non-compliance may lead to bond enforcement, customs-duty recovery with interest, and penalties.

Risk-based selective physical boarding at Karwar Port is determined through advance profiling based on compliance history, voyage details, cargo, operational conduct and declarations relating to crew effects, ship stores and satellite devices. Vessels not selected for boarding receive Entry Inward on advance electronic data, placing heightened responsibility on the Master and Shipping Agent for accurate declarations and safeguarding onboard stores. The Master must prevent prohibited unlading or consumption of restricted, high-duty or non-manifested goods, while the Shipping Agent must promptly report logistical, itinerary and documentation changes.

System-based e-scheduling through the ICEGATE Examination Application permits importers, IEC holders and authorised Customs Brokers to schedule, view and reschedule physical examination of imported goods. Examination slots are allocated according to officer availability, with online status visibility, automated stakeholder notifications and audit trails. Rescheduling, placing examinations on hold, or removing them from the schedule requires recorded and justifiable reasons by the Assistant or Deputy Commissioner in charge. Importers must provide correct Bill of Entry and Custodian/CFS Code details, while custodians and Customs officers must coordinate placement, officer mapping and examination conduct through the application.