Revision under section 263 cannot extend to matters already considered in an appeal: where the appeal covered the genuineness of purchases and profit estimation, Explanation 1(c) barred revision on those purchases. Revision also cannot substitute the Commissioner's view for the Assessing Officer's plausible view after inquiry; having examined supporting documents and estimated only the profit element in unverifiable purchases, the assessment could not be revised to tax the entire purchases as unexplained expenditure. Further, a supplier's non-genuineness alone does not establish remission or cessation of a trading liability, so the outstanding credit could not be taxed on that basis. The revisionary order was set aside and the appeal allowed.

Rejection of books of account for failure to maintain quality-wise diamond stock records requires material showing that the accounts are incorrect or incomplete. The note states that absence of particulars such as size, clarity, colour and shape, without specific defects in books, registers, inventory, vouchers or primary documents, does not justify invoking section 145(3). It further notes that consistently followed accounting methods, supported by stock valuation reports and audit records and accepted in other scrutiny assessments, undermine a best-judgment profit estimate lacking a rational basis. On these stated facts, the rejection of books was treated as unsustainable and the consequential estimated-profit addition was deleted.

Foreign tax credit for overseas legal and consultancy receipts is examined under the India-Japan DTAA and Rule 128. The notes state that Article 14 on independent personal services applies to individuals, while the Article 12(4) exclusion for professional services is confined to payments made to individuals; therefore, a partnership firm's Japanese legal-service receipts are not excluded from foreign tax credit on the basis that Article 14 exclusively governs them. Where gross overseas receipts are included in Indian taxable income and supported by Form 67 and authenticated foreign tax-deduction certificates, Rule 128 contains no stated restriction on credit for overseas taxes withheld.

Higher depreciation was allowed for commercial vehicles acquired during the specified period and included in the relevant asset block. Warranty provisions were allowed because they were scientifically determined, consistently applied and inextricably linked to sales rather than contingent liabilities. For approved in-house research facilities, approval of the facility was treated as material, while the difference between approved and incurred expenditure was remitted for limited verification. Expenditure disallowance relating to exempt income was deleted: joint-venture investments produced no exempt income, and interest-free funds exceeded investments yielding exempt income. The deduction for employing new workmen was allowed consistently with earlier years. Both appeals succeeded, subject to limited verification of the research deduction.

Foreign life-insurance policy maturity proceeds were not treated as undisclosed foreign income or an undisclosed foreign asset where the investment source was satisfactorily explained. Premiums had been paid from income not chargeable to tax during non-resident status and later from salary already taxed in India; CBDT clarifications on explained foreign assets were stated to apply. The discussion also states that the life-insurance exemption does not confine its benefit to policies issued by Indian insurers. A definition of "insurer" in another provision could not be imported where the exemption provision did not adopt it or distinguish foreign insurers. Accordingly, the maturity proceeds were described as exempt and outside assessment under the Black Money Act.

Section 80P deduction for interest and dividend income from compulsory, fixed and savings-bank deposits is discussed as available where the deposits are attributable to a credit co-operative society's business of providing credit facilities to members. The note distinguishes investment income treated as business income from the contrary context of investments with co-operative banks. It also addresses reassessment beyond three years, stating that the extended limitation period requires strict satisfaction of statutory conditions and cannot rest on cash-deposit allegations that do not survive; a deduction disallowance alone must meet the applicable threshold. Consequential under-reporting penalty proceedings may require fresh consideration where the underlying assessment is restored.

A return filed in response to a notice under section 148, when filed within the period specified in that notice, is treated under section 148(2) as a return furnished under section 139. Read together, sections 148 and 80AC permit a deduction claim where the reassessment return is timely, notwithstanding that no original return was filed under section 139(1). The text also explains that revision under section 263 is not warranted where the assessment record shows that the deduction claim was examined and allowed after application of mind; the assessment order must be both erroneous and prejudicial to Revenue interests.

Sale consideration from inherited residential property is addressed as taxable under "Capital gains" where title documents, society records and devolution support the taxpayer's ownership. The material emphasises that doubts about a transfer deed based on unverified signature comparison, without expert evidence or independent enquiry, cannot displace documentary title; suspicion cannot substitute cogent evidence. It further notes that receipt of gross sale proceeds alone does not establish taxable income under "Income from other sources" if ownership is disputed. The described treatment requires computation of long-term capital gains and consideration of the residential-property reinvestment deduction, subject to arithmetical verification.

Cross-examination is required in benami adjudication where a retracted income-tax statement is the foundational evidence for alleging that another person provided the purchase consideration; reliance without testing the statement can undermine findings with confiscatory or penal consequences. Income-tax assessment and benami proceedings operate independently, so acceptance of an investment's source does not conclusively negate benami ownership, but an assessment addressing the same fund flow must be considered. For company-owned property, the Initiating Officer must establish that another person supplied consideration and would benefit from the property, and must give reasoned consideration to documented explanations based on reserves, loans and advances.

Pending representations for provisional release of seized imported glass beads and currency must be considered by the Proper Officer after affording the petitioner an opportunity of hearing. The HC directed the Proper Officer to decide the existing representation and any additional representation concerning the subsequent seizure by a reasoned order in accordance with law within three weeks. The writ petition was disposed of without adjudicating the merits of the parties' rival contentions.

Declared customs transaction value may be rejected only on cogent evidence of extra consideration or reliable contemporaneous imports of comparable goods at higher prices. The notes state that unsupported statements, uncertified electronic records, and uniform loading without consignment-specific comparability do not establish undervaluation. Where final assessments were made and no fraud, collusion, wilful misstatement, or suppression with intent to evade duty is proved, the extended demand period is unavailable. If the valuation-based demand fails, consequential duty, confiscation, interest, and penalty cannot stand; seized currency lacking a proven nexus must be released, and investigation deposits must be refunded with applicable interest.

Belated re-testing of remnant iron ore samples cannot displace contemporaneous representative-sample results without objective, legally sustainable grounds. The notes state that samples analysed at export were corroborated by load-port and discharge-port reports, contractual price adjustments and realised sale proceeds. A re-test conducted more than a year after export was considered unreliable because storage and laboratory drying could affect moisture content and could not recreate the goods' condition at export. The delayed re-test and final assessment based on it were set aside, and the exported iron ore fines qualified for export duty and cess exemption on evidence of iron content below the prescribed threshold.

Transaction-value rejection for alleged under-invoicing requires cogent, independent and legally admissible evidence specifically linked to the importer's transactions. Third-party materials, statements concerning other importers, similar declared prices and comparative data do not establish a nexus or common design, particularly without evidence of payments beyond invoice value. Private price publications require proof of source, methodology, reliability and comparability before they can displace declared values. The sequential customs valuation methods must be considered with sustainable reasons before use of the residual method, including comparable contemporaneous imports. Coordinate Bench precedent arising from substantially similar investigations should be followed or distinguished by cogent reasons where it remains operative.

Capital-goods eligibility under the Status Holder Incentive Scrip exemption was considered broad enough to cover accessories used directly or indirectly for manufacturing, including replacement, modernisation, technological upgradation and expansion. Gaskets, bushings, bearings, gear reducers, springs, bottom parts and shock absorbers imported for plant modernisation were treated as capital goods under Notification No. 104/2009-Cus. The reported CESTAT reasoning states that the 10% restriction applies only to components, spares and parts of capital goods imported earlier, not to capital goods or accessories imported for a new plant or modernisation. Accordingly, the exemption was correctly availed and the duty demand, interest and penalty were set aside.

Transferable DFIA licences remained valid despite penalties imposed on the exporter, as they were not cancelled. The text explains that where proceedings against the exporter resulted in the duty demand being dropped and allegations against the importer were unproved, the importer could not be treated as having used fraudulent means to make duty-free imports. Those circumstances also did not justify invoking the extended limitation period. The customs-duty demand was therefore dropped, and the Revenue's appeal against that outcome was dismissed.

Revenue must prove country-of-origin misdeclaration through reliable, authenticated evidence; unauthenticated foreign customs intelligence and unsupported electronic material may trigger investigation but cannot conclusively establish origin. Where origin misdeclaration is not proved, confiscation and related fines or penalties founded on that allegation cannot stand. Goods already cleared for home consumption after examination cannot subsequently be confiscated for absence of phytosanitary certificates because they cease to be imported goods. Seized goods lacking the required certificate remain liable to confiscation, but may be released on redemption and production of the certificate. A penalty cannot be imposed under Section 112 unless the show cause notice proposed that penalty.

Pelargonium sidoides root extract obtained by hydro-ethanolic extraction, solvent removal through vacuum drying and addition of Maltodextrin as an inert carrier is addressed as a vegetable extract rather than a medicament. The notes explain that vacuum drying normally produces a solid extract and does not, without supporting evidence, establish concentration, further extraction or purification that would exclude classification under Heading 1302. An inert carrier used for handling, drying or standardisation does not alter the extract's essential character. Bulk supply as pharmaceutical raw material, without mixed active medicinal constituents, measured doses or retail presentation, does not itself support medicament classification. The stated customs exemption applies subject to prescribed conditions and assessment-stage verification.

Section 60(5) gives the Adjudicating Authority broad jurisdiction over questions arising out of or relating to corporate insolvency resolution, requiring an interpretation that supports expeditious resolution and preservation of asset value. Directions to suspended directors of a lessee corporate debtor to assist the resolution professional of the lessor corporate debtor in identifying and recovering leased electric vehicles had a direct nexus with the insolvency process. Their objection to being directed individually was inconsistent with their acknowledged responsibility to provide relevant information and assistance. The NCLAT upheld the cooperation directions and dismissed the appeal.

An Interim Resolution Professional must receive, verify and collate claims and maintain an updated creditor list for constituting the Committee of Creditors. Partial admission of secured creditors' claims after verification, and their reduced voting share following admission of homebuyers' claims, do not by themselves establish lack of integrity or justify removal. Decisions to retain or replace the professional ordinarily remain within the Committee of Creditors' commercial wisdom, with tribunal intervention limited to exceptional circumstances. Allegations of bias, misconduct, contractual interference and process deadlock did not establish such circumstances, particularly where the relevant contract resolution was stayed and class creditors supported the professional. The applications for replacement and restraint on further committee meetings were rejected.

Constitutional judicial review under Article 226 may extend to an Enforcement Case Information Report (ECIR) and consequential proceedings under the PMLA where they underpin coercive action affecting liberty, property or reputation. Although an ECIR is characterised as an internal administrative document rather than an FIR, that characterisation does not bar constitutional scrutiny. Decisions declining to quash an ECIR under the inherent jurisdiction in Section 482 CrPC do not limit the broader scope of Article 226 review. The High Court may examine the ECIR's legality together with the connected proceedings, avoiding fragmentation of a single cause of action. The preliminary objection was rejected and the writ petition was held maintainable for consideration on merits.