Limitation for customs appeals may permit exclusion of time spent pursuing a remedy before the wrong customs office under Section 14 of the Limitation Act, particularly where that office neither transfers nor promptly returns the appeal. An appeal transmitted by e-mail within the prescribed period, with a physical copy dispatched the same day, may also be treated as timely or within the condonable period. Refund of excess duty paid under protest may be available where final Bills of Entry accept the importer's declared classification and Revenue has neither challenged nor reopened those assessments. Each finally assessed Bill of Entry is independently determinative; refund does not extend to provisionally assessed Bills of Entry.

For inland seizure of unmarked gold, diamond jewellery and cash, reasonable belief of smuggling must rest on pre-seizure material and prima facie proof of foreign origin. In the absence of foreign markings, corroborating forensic or documentary evidence, or proof of importation or statutory prohibition, Section 123 does not shift the burden of proving non-smuggled character to the assessee. Investigation statements cannot alone support confiscation or penalties unless statutory conditions governing their evidentiary use are met and independent corroboration exists. Domestic procurement invoices available on the GST portal, with no disputed genuineness, supported release of the goods and cash; confiscation and penalties were unsustainable.

Penalty for shortage of duty-free gold and silver requires reliable proof of deliberate diversion or intent to evade duty; a reported theft, voluntary payment of duty and interest, and absence of revenue loss do not by themselves establish penal liability. Untested statements cannot support penalty unless the statutory safeguards for their use are met, and an unverified recovery not linked to the missing goods provides no independent corroboration. Penalties on the proprietorship concern, its supervising individual, and the person alleged to have removed the goods were therefore set aside. Differential customs duty and applicable interest on the stock shortage remained payable. Separate penalty on the proprietor was impermissible because a proprietorship concern and its proprietor are not distinct legal persons.

A Customs Broker's acceptance of examination findings does not bind an importer on classification or valuation unless the broker has authority to act for the importer. Attendance by the broker and a Chartered Engineer at examination does not itself establish the importer's presence or acceptance, and treating it as such breaches natural justice. Reclassification and revaluation require reliable evidentiary support, including appropriate specialist opinion, testing or market enquiry where the goods' nature is disputed. Where alleged steel coils were claimed to be damaged scrap intended for melting and the claim was not disproved, misdeclaration, confiscation, redemption fine and penalty were unsustainable.

Amendments to customs provisions operate prospectively unless retrospective effect is expressly provided. An amendment effective from 15 June 2026 cannot govern goods imported under a Bill of Lading predating its commencement. Accordingly, the amendment cannot be used to decline consideration of provisional release. Where similar goods have previously been directed for provisional release and no distinguishing feature is established, the request requires consideration under Section 110A.

Interim safeguards for clearance of ongoing and future imports required a balance between the Revenue's duty-recovery interests and the importer's entitlement under the existing appellate order. Arguable issues were reserved for final hearing, making an unconditional stay inappropriate. Pending the appeal, the importer may provisionally clear consignments by furnishing a bond covering the full differential duty and a bank guarantee for 50% of that duty.

Imported laser imagers that merely print data received from diagnostic equipment lack independent diagnostic capability and are accessories rather than diagnostic instruments. Under Chapter 90 Note 2(b), accessories are classified with a machine only when suitable solely or principally for a particular kind of machine or machines within the same tariff heading. Because the imagers were compatible with equipment classifiable under both CTH 9018 and CTH 9022, they could not be classified with either single heading. Chapter 90 Note 2(c) therefore applies, placing them under residual CTH 9033 00 00 as accessories not specified or included elsewhere in Chapter 90.

Properties acquired in the appellants' names were treated as benami because the alleged beneficial owner paid the consideration, while the registered owners failed to prove independent financial capacity or substantiate the asserted loan arrangement. No statutory exception applied. The future-benefit requirement under Section 2(9)(A) was satisfied because benefit need not be immediate, time-bound, or realised when provisional attachment is imposed; the beneficial owner's access to and use of undisclosed funds supported the inference of future benefit. Confirmation of provisional attachment of the three properties was therefore sustained.

Provisional attachment of property was sustained under Section 2(9)(D) of the Prohibition of Benami Property Transactions Act, 1988, because the claimed loan-funded consideration lacked credible evidence. The alleged lenders' financial capacity, income-tax records, repayment and interest payments were not established, while unregistered loan documents lacked authenticity in the circumstances. Cash consideration, delayed validation of sale documents, and failure to explain the source of the remaining payment and validation fees further undermined the stated source of funds. The transaction was treated as benami because the persons providing consideration were not traceable or were fictitious.

TNMM requires primary focus on functional comparability. Reliable segmental data for indenting services may support use of that segment as a comparable for marketing-support commission despite the enterprise's predominant trading activity, where functions, assets and risks are similar. Foreign-currency loans to wholly owned associated enterprises may be benchmarked against LIBOR with an additional risk spread only if differential credit risk or other risk factors justify it. Delayed associated-enterprise receivables constitute an international transaction, but a separate interest adjustment should not duplicate the time-value impact already captured through an appropriate working-capital adjustment. Verification of working-capital-adjusted margins determines whether a separate receivables adjustment is required.

Delayed registration of an immovable-property agreement does not by itself constitute a fresh receipt of property under Section 56(2)(x)(b) where consideration was paid, possession delivered, and substantive ownership rights exercised under an earlier agreement. Registration that merely formalises an already concluded transaction creates no new taxable receipt; prior acceptance of rental income from the property is inconsistent with treating registration as the first receipt. Consequently, the addition was deleted. Penalty for under-reporting under Section 270A cannot survive where it rests exclusively on that deleted addition, because no under-reported or misreported income remains.

Audited segmental data should govern functional comparability in transfer-pricing analysis where it separately identifies a comparable's trading results; entity-level trading-income filters should not displace those segmental results. A company engaged exclusively in trading may satisfy the trading-income filter where its financial data supports that characterisation. Delayed receivables from associated enterprises may constitute a separate international transaction, but no independent notional-interest adjustment should arise if the working capital adjustment already captures the receivables differential against comparables. The arm's length price should accordingly be recomputed using the identified trading comparables, without duplicating the receivables adjustment.

Section 153D approval must demonstrate independent, assessment-year-specific application of mind to the relevant issues and seized material; a consolidated mechanical approval can vitiate the assessments. Materials seized from a director managing the company's day-to-day affairs during a simultaneous search may be used in the company's section 153A assessment without resort to section 153C. For unabated years, a consistently applied Project Completion Method cannot be replaced by an arbitrary Percentage Completion Method estimate where no incriminating material is found and the accounts are not rejected. Receipts and payments recorded in the same seized papers cannot generate separate income additions where the related income was already offered and assessed.

Revisionary jurisdiction cannot be invoked solely because the Assessing Officer did not initiate penalty proceedings for under-reporting or misreporting of income while completing reassessment. Penalty proceedings are independent of assessment proceedings, so omission to record or initiate penalty action does not make the assessment order erroneous and prejudicial to the Revenue. A contrary coordinate-bench view was distinguishable because it had not considered the binding High Court authority applied here. Revision founded only on non-initiation of penalty proceedings was therefore invalid.

Bona fide delay in claiming exemption for BSNL VRS-2019 compensation may be condoned where comparable employees have obtained similar relief and rejection on limitation would prevent consideration of an otherwise recognised claim. Government-approved and funded ex-gratia compensation under the BSNL Voluntary Retirement Scheme-2019 is treated as retrenchment compensation eligible for exemption under Section 10(10B). A prior offer of the amount to tax and processing of the return under Section 143(1) do not bar a fresh exemption claim. The Assessing Officer must verify eligibility, allow the exemption, determine consequential tax payable or refundable, and grant admissible interest under Section 244A.

Exemption under Section 11 is not denied solely because Form 10B was furnished after the prescribed time where the audit report accompanied the return and was available with the processing authority before return processing. Procedural delay in furnishing the audit report does not defeat a charitable institution's exemption claim if the report is available at the assessment or processing stage and remaining statutory conditions are fulfilled. Denial of exemption also does not justify treating the institution's entire receipts as income without computation on commercial principles.

Reassessment notices must conform to the faceless, algorithm-based assessment framework where prior rulings require that process. Where the final assessment order is already challenged before the Commissioner of Income Tax (Appeals), writ adjudication of the jurisdictional objection may render the statutory appeal redundant. The appellate authority must consider the objection to the Jurisdictional Assessing Officer's notice consistently with the applicable prior rulings, and the taxpayer must seek appropriate relief through that appeal within the stipulated period.

For search-based reassessment where the search falls within Section 152(3), the pre-Finance (No. 2) Act, 2024 regime applies. The first proviso to Section 149(1) adopts the limitation framework of Sections 153A and 153C for assessment years beginning on or before 1 April 2021. Under Explanation 1 to Section 153A, the ten-year period runs from the end of the assessment year relevant to the financial year of search. For a search in financial year 2024-25, the permissible ten-year block extends from AY 2016-17 to AY 2025-26; AY 2015-16 falls outside it. A reassessment notice for AY 2015-16 is therefore beyond limitation and without jurisdiction.

Final assessment orders issued while timely objections to a draft assessment order remain pending before the Dispute Resolution Panel cannot stand if they conflict with the Panel's binding directions. An eligible assessee invokes the statutory procedure under Section 144C by filing objections within time, requiring completion of the assessment in conformity with those directions. Failure to intimate the Assessing Officer of the objections was a bona fide lapse that conferred no advantage and did not displace the binding effect of the Panel's directions. Where the transfer-pricing order underlying the assessment was revised pursuant to those directions, the final assessment, consequential demand and penalty-initiation notices were invalid; a fresh assessment was required.

Interim restraint on processing income-tax returns filed by sitting judges was modified because the automated system could not independently identify those returns. Identification details were required to enable exclusion of the relevant returns from processing while allowing other returns to be processed without disruption. The modification application was disposed of, and the writ petition remains pending without final adjudication.