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.

GST appellate procedure distinguishes additional grounds of appeal from additional evidence. Section 107(10) permits an appellant, subject to statutory conditions, to raise an omitted ground, while Rule 112 separately regulates evidence not produced in earlier proceedings. Rule 112 permits additional evidence only in specified circumstances, requires written reasons for admission, and protects the Department's opportunity to examine, cross-examine or rebut it. Contested departmental material at the appellate stage requires a real opportunity to challenge its admissibility, authenticity, relevance and evidentiary value.

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.

Customs brokers may adopt a bona fide, plausible tariff classification during self-assessment when it is supported by documents available at clearance. Their duty to advise clients requires diligent declarations, while due diligence requires reasonable care in information provided; neither requires predicting a later departmental view on a debatable classification. Where competing tariff entries are plausible and there is no false factual declaration, knowledge of misdeclaration, inaccurate information, or connivance, the broker does not breach these obligations. Licence revocation, security forfeiture, and penalty cannot rest solely on subsequent departmental disagreement with the classification.

The first proviso to Section 129A(1) of the Customs Act excludes appellate jurisdiction over orders concerning goods imported or exported as passenger baggage. Gold brought into India by an international passenger remains baggage even if recovered from the passenger's trouser pocket rather than luggage. Non-declaration or concealment allegations concern the merits of confiscation and penalty and do not alter the statutory jurisdictional exclusion. Maintainability depends on the nature of the goods and transaction, not the relief sought. The applicable remedy for a baggage-related confiscation order lies in revision under Section 129DD before the competent Revisional Authority.

Section 123 of the Customs Act shifts the burden of proving lawful acquisition only after seizure on a reasonable belief of smuggling founded on relevant material. Domestic courier transport and absent documents may justify investigation but, without proof of illegal importation or a valid presumption, do not establish that gold is smuggled. Confiscation based on concealment, unauthorised removal, or prohibited import requires the respective statutory conditions to be independently met. Penalty for dealing in smuggled goods requires an identified act or omission making goods confiscable and knowledge or reason to believe; jewellery trading and undocumented transport alone are insufficient. Confiscation and personal penalty were set aside, with consequential relief to follow.

Rectification proceedings initiated and decided in the name of an entity dissolved before the notice and order are invalid where the assessing authority had been informed of the dissolution. An order against a non-existent entity constitutes substantive illegality, not a procedural defect capable of cure under the statutory saving provision. Participation in the proceedings cannot validate the order, because estoppel cannot operate against law. The rectification order is therefore a nullity and must be quashed.

Section 69A requires cash-deposit explanations to be assessed against available evidence and the preponderance of probabilities. Verified earlier bank withdrawals may support a cash-flow explanation where no evidence shows that the withdrawn cash was non-genuine, spent, or otherwise deployed; suspicion based on cash retention, withdrawal frequency, or demonetisation-period deposits is insufficient. Section 68 applies only to credits recorded in books of account maintained by the taxpayer. Bank-account or passbook entries alone do not constitute such books. Taxation under section 115BBE and consequential interest depend on a sustainable addition for unexplained money or credits.

Section 269SS prohibits accepting specified loans or deposits in cash, and section 271D imposes a penalty for breach. Relief under section 273B requires the assessee to establish reasonable cause. A spousal or family arrangement does not remove each spouse's independent tax obligations. Where both spouses had banking facilities, an earlier loan was advanced by cheque, and no explanation justified later cash acceptance, reasonable cause is not established. Repayment by cheque does not cure the breach, because the contravention occurs on acceptance of the cash loan or deposit; the penalty therefore remains sustainable.