Article 141 makes the Supreme Court's declared law and unambiguous directions binding on all courts. A trial court must implement an express direction for immediate vacant possession where an undertaking binds all accused; it cannot use inherent jurisdiction under the Bharatiya Nagarik Suraksha Sanhita, 2023 to reinterpret, dilute, or sit in appeal over that direction. A pending review petition does not suspend the operative force of the judgment unless the Supreme Court grants a stay, modification, or suspension. The direction requiring the accused to vacate the residential quarters therefore remains enforceable.

Technical meaning governs the scope of the customs concession for Train Protection and Warning System (TPWS) equipment. Railway specifications distinguish track-side and on-board TPWS signalling equipment from interfaces with brake-control systems. Disc Brake Units and Pole Wheels, which form part of axle-mounted disc braking and wheel-slide protection systems, therefore do not qualify as TPWS parts or components and cannot receive the concessional duty rate. Strict construction requires the exemption claimant to establish square coverage. Where a notice invokes only the normal limitation provision for duty recovery, differential duty may be demanded only for Bills of Entry within that period; recovery beyond it requires invocation of the extended-period provision.

Under the Customs Act, the burden-shifting presumption for gold arises only where seizure rests on a seizing officer's reasonable belief, supported by definite and objective material, that the goods are smuggled. Without that foundation, the Department must independently establish illicit importation through cogent evidence before confiscation or penalties can follow. Domestic procurement records, payment trails, stock and tax records, and transport or melting documents require effective rebuttal; uncorroborated or retracted statements alone do not prove smuggling. Cross-examination is required when specifically sought for relied-upon witness statements; absent such a request, its non-grant does not itself breach natural justice.

Under Advance Authorisations, the physical-incorporation requirement for satisfying export obligation applies to imported inputs used in the resultant export product. Imported Vetted Malt Scotch physically incorporated in exported IMFL meets that condition; separately procured duty-free bottles, caps and labels used only for packing do not constitute inputs physically incorporated in IMFL. Their use therefore does not, by itself, breach the relevant exemption condition or invalidate export-obligation fulfilment. For customs-duty recovery, DRI officers may issue notices when appointed as customs officers and assigned the relevant recovery function, which is distinct from assessment.

Provisional release of seized betel nuts under the Customs Act was not warranted where testing did not establish unequivocal Indian origin. Initial sampling indicated resemblance to Indonesian areca nuts and mould infestation; re-sampling reported Indian origin but did not address mould. Food-laboratory findings that the nuts were mould- and insect-damaged beyond prescribed limits, sub-standard and unsafe supported non-release. The availability of an appellate statutory remedy meant that challenges concerning seizure and release could be pursued through that remedy.

Paragraph 1.05(b) of the Foreign Trade Policy, 2023 provides transitional protection for bona fide import commitments made before a restrictive import notification. Although the provision expressly refers to irrevocable commercial letters of credit, substantial advance payments may provide equivalent or greater payment security to overseas sellers where business records establish genuine pre-existing transactions. The restriction on gold imports remains a policy decision, but its transitional application requires a purposive construction. Delegated legislation ordinarily operates prospectively unless retrospective operation is statutorily authorised. Pre-notification gold import transactions supported by substantial advance payments qualify for the transitional benefit.

Section 110(5) of the Customs Act limits provisional bank-account attachment to six months, extendable once by a competent Commissioner in writing for up to a further six months, with communication before the original period expires. The maximum attachment period is therefore twelve months. A show cause notice under Section 124 or pending adjudication does not extend that limit. Once the maximum period expires, the attachment ceases by operation of law and cannot continue through administrative action.

Availability of an efficacious statutory appeal ordinarily calls for restraint under Article 226 but is not an absolute bar to writ jurisdiction. A challenge to treating goods as prohibited solely by description and asserted criminal-law application, without an identified statutory or notification-based prohibition, raised an arguable departure from objective legal standards affecting the right to trade. The preliminary alternative-remedy objection was rejected, the writ petition was maintainable, and the merits remained for hearing.

Prior approval for provisional attachment under Section 24 of the Prohibition of Benami Property Transactions Act, 1988 must follow issuance of a written notice to the alleged benamidar, founded on recorded reasons to believe, with a copy to the beneficial owner. Attachment may be ordered only after the prescribed opinion is formed and the Approving Authority grants approval on the relevant material and reasons. Approval obtained before the statutory notice is issued is invalid because it bypasses the mandated sequence, lacks the necessary evidentiary basis, and makes the attachment process mechanical. Consequently, a provisional attachment based on such prior approval, and its confirmation, cannot be sustained.

Section 115BBE's enhanced tax rate, introduced by the 2016 amendment with effect from 1 April 2017, applied to surrendered income for assessment year 2019-20. As the amendment was already operative for that year, taxation at the normal rate was a mistake apparent from the record and could be rectified. The surrendered income was therefore chargeable at the enhanced rate.

Section 56(2)(vii) did not support an addition where the difference between purchase consideration and DVO valuation fell within the applicable tolerance band. The Section 50C(2) valuation mechanism was treated as pari materia, extending its tolerance to that valuation difference; the stamp-duty-based addition was therefore deleted. Investment and stamp-duty payments traceable to the taxpayer's disclosed bank account and available balance constituted an explained source of funds. The unexplained-investment addition was consequently deleted, resulting in deletion of both property-acquisition additions.

Business-expenditure deductibility under sections 28(i) and 29 requires an expense-wise factual inquiry into whether legal and professional costs were incurred for continuing or preserving the business. Transfer of a branch undertaking on a going-concern basis did not itself resolve the position where statutory assets remained with the taxpayer. As the purpose of retaining those assets and the connection of the predominant expenses with business purposes or pending branch litigation were not established, the claim against interest on an income-tax refund requires fresh determination through de novo assessment.

Differences between FCRA disclosures and income-tax return reporting cannot be treated as undisclosed income through a section 143(1) adjustment merely because the FCRA figure includes interest earned on invested foreign contributions. FCRA and income-tax disclosures serve different statutory purposes and require reconciliation based on substance rather than form. Where foreign contributions and related interest are separately declared, accounts are audited without qualification, the reporting approach has been accepted in other years, and supporting explanations are provided in rectification proceedings, a prima facie adjustment is unsustainable. The addition was deleted.

Penalty for an alleged breach of cash-transaction restrictions requires cogent proof of the underlying cash receipt, even though penalty proceedings are independent of assessment proceedings. The Revenue did not produce demonstrative evidence supporting the alleged cash receipt used as the basis for penalty; the larger amount rested on conjecture and differed from the amount recorded in the available material. As the essential cash transaction was not proved, penalty was not leviable.

Appellate confirmation of a penalty exceeding the Assessing Officer's levy requires prior notice of enhancement. Erroneous entries in an appeal form that record surrendered income as penalty amounts do not justify confirming a higher penalty without that notice. Penalties therefore remain restricted to the amounts originally levied, although liability for penalties at those original amounts remains sustainable on the recorded facts.

Section 144C treats objections to a draft assessment order filed after the prescribed thirty-day period as time-barred. Where no valid objections exist, the Assessing Officer must complete the assessment under the draft-assessment procedure within one month from the end of the month in which the objection period expires. This statutory limitation is mandatory and is not extended by pending disposal of belated objections before the DRP. A final assessment order made after that period is void ab initio and liable to be quashed.

Rectification orders under Section 154 are appealable under Section 246A, and dismissal of such an appeal as non-appealable cannot deny merits-based consideration of a claim for the concessional tax rate under Section 115BAB. Allocation of an appeal to a particular first appellate authority under the faceless regime does not prejudice the taxpayer's statutory right to appellate review. The concessional-rate claim requires adjudication on merits by the first appellate authority in accordance with principles of natural justice.

Assessment and consequential rectification founded solely on a revision order cannot survive after that revision order is quashed. The loss of the revision order removes the legal foundation for both consequential actions, rendering them non est. A pending Revenue challenge does not independently preserve the assessment or rectification where the sole revisionary foundation no longer exists.

Relevant shipping income under the Tonnage Tax Scheme is confined by section 115VI and Rule 11R to core ship-operating or dredging activities and prescribed incidental activities with a direct operational nexus. Scrap, empties, waste oil, exchange differences, insurance claims and provision write-backs qualified, while tender-document receipts, liquidated damages, salary recoveries, training fees and other operating income did not; service charges received differing treatment across the relevant assessment years. Sponsorship for the Maritime India Summit was deductible under section 37(1) because it promoted business activities and had a commercially expedient connection with future operations, despite being described as a donation.

Functional similarity is the primary criterion for selecting comparables under the Transactional Net Margin Method for routine IT-enabled back-office services; companies performing specialised, higher-value services should be excluded despite meeting quantitative filters. Employee-cost filters cannot be applied mechanically where costs are embedded in service expenses or disclosed only at entity level; functionally similar companies should not be rejected solely on that basis. Outstanding receivables may constitute an international transaction, but a separate notional-interest adjustment requires proof of an independent financing arrangement and economic benefit beyond working-capital effects already reflected in the profit-level indicator. The arm's length price is recomputed using the revised comparable set without a separate receivables adjustment.