Electronic records recovered from an accounts manager, together with signed printouts and statements confirmed by the manager and director, can constitute corroborative evidence of unaccounted cash receipts from flat purchasers. Facts concerning records maintained exclusively by those persons place the evidentiary burden on them under the rule governing facts within exclusive knowledge. Voluntary statements recorded during investigation remain usable evidence where a retraction is delayed and raised only in response to a show-cause notice. The absence of bank entries or purchaser statements does not by itself negate the evidentiary value of such electronic records and confirmations for service-tax liability.

Money-laundering bail was denied where material, including an independent audit, indicated alleged diversion of funds collected from allottees. The applicant's conduct was also considered to have delayed trial progress. These circumstances supported refusal of bail in the money-laundering proceedings, with the evidentiary material and trial delay forming the key considerations.

ECIR proceedings under the Prevention of Money Laundering Act require proceeds of crime derived from criminal activity linked to a subsisting scheduled offence. Quashing the sole predicate FIR removes the scheduled-offence foundation and leaves no basis to continue money-laundering action against persons or property connected with that FIR. The ECIR was consequently quashed for the petitioners and their associated directors, partners, employees and shareholders.

Conditional property-transfer arrangements used to secure or facilitate payment do not novate or discharge an operational debt unless they completely substitute, rescind, or extinguish the original obligation under contract law. Where the original liability is expressly preserved, payment and transfer have not occurred, and cheques for admitted dues are dishonoured, the operational debt remains enforceable through Section 9 insolvency proceedings. A pre-existing dispute must genuinely and substantively concern the operational claim; a collateral controversy over property transfer or specific performance, without contemporaneous evidence disputing supplied goods, amount, or liability, does not bar insolvency admission.

IBC moratorium under Section 14(1)(a) does not bar arbitral proceedings initiated by a corporate debtor through a counterclaim, because an unsuccessful counterclaim creates no pecuniary liability and a successful one may augment the estate. A pre-CIRP termination of a development agreement for non-performance does not make the terminated agreement estate property protected by the moratorium. Interim arrangements may therefore be reconsidered in aid of the surviving counterclaim. Section 60(5)(c) grants only limited residuary insolvency jurisdiction; where contractual termination predates and is unrelated to CIRP, the required nexus is absent, Section 63 creates no jurisdictional bar, and arbitral jurisdiction continues. An inaccurate description of a Section 29A extension does not alter that result if the application concerns the counterclaim.

An approved resolution plan becomes binding between the Committee of Creditors and the successful resolution applicant upon approval under Section 30(4), before Adjudicating Authority approval under Section 31(1). Section 12-A and Regulations 30-A and 18(2) permit withdrawal only until the Committee approves the plan. The Committee's continuing role in implementation does not permit alteration or withdrawal of a plan submitted for approval. The Adjudicating Authority examines statutory compliance under Sections 30(2) and 31(1); improved financial performance alone does not justify rejecting a compliant plan.

Modification of an advance ruling is available only for a mistake of law or fact under Regulation 21, while rectification under Regulation 22 is confined to a mistake apparent from the record. Neither mechanism permits reconsideration on merits or removal of an express condition governing a customs exemption. Exemption under Notification No. 134/94-Customs remains conditional on undertaking the prescribed operations in accordance with Section 65 of the Customs Act, 1962. Operational difficulties, bonds, traceability records, or conditions under other notifications cannot replace that mandatory requirement.

Transferable DFIA entitlement permits duty-free import of Inshell Walnuts where they fall within generic SION input descriptions and the authorisation endorses the applicable description, quantity and value. Specific input and quantity must be declared in export documents; technical correlation is required only for sensitive inputs. Eligibility remains subject to DFIA validity and express notification conditions. Substantive restrictions on that entitlement, including percentage-based CIF value caps and an Actual User Condition, require imposition through the prescribed Official Gazette notification mechanism. Restrictions introduced solely by public notice cannot independently deny exemption under a valid transferable DFIA.

Customs valuation treats declared transaction value as the primary basis for imported goods. Before rejecting it under Rule 12, the importer must receive the grounds for doubt and supporting valuation material. NIDB data or routine benchmark values cannot justify enhancement unless comparable-import particulars, including origin or export country, producer, commercial level and quantity, are established; subsequent valuation methods must then be applied sequentially. Examination-based differences do not by themselves establish intentional misdeclaration without material showing fraud, suppression, wilful misstatement or intent to evade duty. On those principles, valuation-based differential duty, confiscation, redemption fine and penalties lack a sustainable basis.

Standard electronic-design and simulation software supplied to varied educational users remains packaged rather than customized software where consultations, installation, training, and technical support do not involve client-specific development or alteration. The customized-software exemption is consequently unavailable. RSP/MRP-based assessment applies where software is capable of off-the-shelf sale and lacks the required "not for retail sale" package declaration for institutional or industrial consumer treatment. Contemporaneous distributor and reseller invoices may establish RSP under the valuation rules, with prescribed abatement, where support services are not separately charged. Absence of mandatory declarations and subsequent corrective labelling can support extended limitation, confiscation, and penalties for duty evasion.

Cash transferred by a beneficial owner to another person for deposit in that person's bank account can constitute a benami transaction under the Prohibition of Benami Property Transactions Act, 1988. Cash is movable property and may simultaneously serve as the property held for the beneficial owner's benefit and as the consideration supplied by that owner. A recipient who deposits the cash in a personal or proprietorship account and lends their name may be a benamidar; prompt retransfer through banking channels does not negate temporary holding for the owner's benefit. Attachment should be limited to the residual available balance and the applicable interest-free bond after tax payment and deposit under the Pradhan Mantri Garib Kalyan Yojana, rather than the entire original amount.

Verification of the payment's character, the recipient's residential status and underlying transaction records is necessary before deleting a disallowance for alleged failure to deduct tax. Application of section 194Q depends on whether payments constitute consideration for goods and are made to residents. Sample transactions and presumptions based on shipping-company names do not establish these conditions. Co-terminus appellate powers require examination of relevant records and potential tax-deduction obligations under applicable provisions. In the absence of adequate factual inquiry, deletion of the disallowance cannot be sustained and requires fresh adjudication by the first appellate authority.

Functional comparability under the Transactional Net Margin Method requires a contemporaneous analysis of functions performed, assets deployed and risks assumed; broad functional similarity alone does not establish comparability. The disputed freight-forwarding comparables require fresh consideration through that analysis, with an opportunity of hearing. A working capital adjustment under Rule 10B(3) may be examined where it improves comparability between the tested party and selected comparables, even if the claim was not raised before the Dispute Resolution Panel. That adjustment requires a merits determination after hearing.

Section 68 applies to credits recorded during the relevant year and generally does not cover opening balances carried forward from prior years. Creditor identity, confirmations, tax records, banking-channel receipts and undisputed repayments are relevant to genuineness, while lenders' creditworthiness may require enquiry under Section 133(6). Capital credits transferred from a deceased parent's bank account require verification of the parent's financial records and availability of funds. Under Section 145(3), a fall in gross-profit rate alone does not justify rejecting books or adopting an earlier rate; estimation requires objective, cogent grounds, considering turnover and actual gross and net profits.

Reassessment under Sections 147 and 148 following a scrutiny assessment under Section 143(3) is invalid where the loan transaction, repayment, lender identity, creditworthiness and genuineness were already examined on material furnished by the assessee. Reopening on that same material, without a fresh tangible basis, constitutes a change of opinion and cannot support reassessment jurisdiction; the reassessment was quashed.

Recorded purchases supported by invoices, bank payments, stock records, and manufacturing consumption could not be treated wholly as bogus when corresponding sales remained undisputed. The books were not rejected under section 145(3), and the assessing authority did not discredit the evidence, question consumption, or challenge sales. A supplier's later identification as an accommodation-invoice issuer, or non-response to notice, did not by itself prove non-receipt of goods in the relevant year. The entire alleged bogus-purchase addition was therefore deleted.

Section 43CA's 10% tolerance band treats small differences between declared consideration and stamp-duty valuation as insufficient to trigger deemed-consideration additions. As a beneficial, curative measure designed to address hardship in genuine real-estate transactions, the tolerance applies retrospectively. Where the difference between declared sale consideration and the District Valuation Officer's valuation remains below 10%, stamp-duty value cannot replace declared consideration, and no addition under Section 43CA is warranted.

Filing the prescribed audit report in Form No. 10B within a due date validly extended by the CBDT satisfies the timing requirement for charitable exemption under sections 11 and 12. Accordingly, exemption cannot be denied during return processing under section 143(1) on the ground of delayed audit-report filing where the report was filed within the extended deadline. Bona fide circumstances preventing timely first appeals, including loss of access to the registered email account and COVID-19-related disruption, may constitute reasonable cause for condoning delay. The charitable exemption remains available where the audit reports are treated as timely filed under the applicable extensions.

Penalty for alleged cash acceptance in a jointly owned property sale was deleted for one co-owner after a registered rectification deed changed the stated cash-receipt dates. The identical transaction had resulted in no penalty for the other equal co-owner. Equal treatment was therefore applied to the assessee in relation to the same cash receipts and property transaction.

Rectification for a mistake apparent from the record is confined to obvious, patent and self-evident errors. Where documentary evidence, explanations for bank deposits and related submissions were considered in the appellate proceedings, dissatisfaction with their acceptance or a request for a different inference does not establish such an error. Rectification cannot be used to review, rehear or reappreciate material already examined on appeal. On these facts, no mistake apparent from the record arose and rectification was unavailable.