Extended limitation for customs duty requires deliberate non-disclosure of material facts with intent to evade duty; prior departmental knowledge and acceptance of the declared classification therefore precluded extended-period liability. Specific classification of woven warp cut-pile fabrics under CTH 5801, rather than headings based on constituent textile material, applied because the pile-fabric heading governed their essential character; the live consignments remained so classified. Alternative CVD and SAD exemption claims may be raised after clearance absent fraud but require fact-based determination of notification conditions, requiring remand for merits review. Prior acceptance also negated blameworthy conduct, so confiscation and penalties did not survive.

Directorate of Revenue Intelligence officers appointed as customs officers and assigned proper-officer functions may issue recovery notices under the Customs Act. Assignment of functions relating to assessment and recovery distinguishes the statutory roles under the relevant provisions and defeats a jurisdictional objection to such notices. Personal penalties for smuggling prohibited goods are sustainable where an admitted arrangement with de facto importers enabled clearance of concealed goods for cash consideration, demonstrating an active and serious role in the operation. The recovery notice and penalties consequently remain valid on these grounds.

Excess export duty first quantified through departmental reassessment is governed by the reassessment date for refund limitation and statutory interest. Refunds based on an alleged legal error must follow the self-contained mechanism under Section 27 of the Customs Act; the Limitation Act and Article 265 cannot independently override that regime. Where the excess payment was not reflected in the original assessment records, reassessment ascertains the refund entitlement, rendering a pending correction request and refund claim maintainable. Interest under Section 27A runs after three months from reassessment until actual payment, at the notified rate.

Section 110A permits bond, security and conditions for provisional release pending adjudication, but requires a case-specific and proportionate exercise of discretion. For non-prohibited goods involving tariff classification and differential-duty disputes, security should correspond to the disputed duty and be assessed on relevant material, including classification test reports. Compliance with interim security to maintain business operations does not end the importer's grievance or appellate entitlement. A tribunal cannot treat revenue protection as sufficient and dispose of the challenge without deciding the validity and extent of the security demand on merits.

Statutory revision under the Customs Act is the appropriate forum for examining confiscation of baggage goods where the alleged waiver of notice and hearing, oral show-cause notice, and their voluntariness and legal effect are disputed. Although an alternative remedy does not absolutely bar writ jurisdiction under Article 226, its exercise is discretionary and is unsuitable where contested factual questions require examination of the record. The legality of confiscation, penalty, and compliance with the notice requirement remains open for determination by the revisional authority in accordance with law.

Mandatory safeguards under Sections 110(2) and 124 of the Customs Act require more than a mechanical pre-printed waiver; such a waiver alone does not meet the notice requirement. Signed contemporaneous statements and a subsequent written acknowledgement may, however, record non-declaration through the Green Channel, receipt of an oral show cause notice, and a request for merits adjudication. Where allegations of coercion, fabricated records, or Red Channel declaration conflict with those records, they require evidentiary assessment and cannot be resolved in Article 226 proceedings. Release of detained gold through mandamus is therefore unavailable absent an undisputed statutory violation, while confiscation and penalty remain for competent adjudication.

Section 123 of the Customs Act shifts the burden of proving lawful acquisition of notified goods only after reasonable belief of smuggling is established through material evidence. Foreign markings, concealment, carrier statements, high purity and inconsistent explanations may support that threshold, while general invoices and stock records lacking a traceable link to seized gold do not discharge the reverse burden. Silver bullion without foreign markings, clandestine transport, or evidence of illicit import does not attract the presumption merely because of stock discrepancies. Indian currency requires cogent evidence connecting it to sale proceeds of smuggled goods before confiscation; suspicion cannot replace proof.

Irrecoverable VAT/CST refund claims arising after sales returns may be deductible as business losses where the tax has been refunded to customers and the loss directly arises from ordinary business activity, even if it is not a bad debt. Export-sale receivables written off after goods are rejected and returned for quality defects may qualify as bad debts where the sales were recognised as income and the amounts are actually written off in the accounts; an earlier year of sale does not by itself defeat the claim. For exempt-income expenditure, availability of own funds may preclude interest disallowance, but administrative expenses may still be disallowed under Rule 8D where the taxpayer's computation is not accepted.

Execution of a registered joint development agreement, coupled with authority for the developer to undertake construction and obtain approvals, did not constitute a transfer under the capital-gains provisions read with the part-performance rule. The owner was entitled to receive her share only after construction, and construction-related access did not itself transfer the property. As the agreement related to an earlier financial year, no long-term capital gain arose in the assessment year in which the addition was made; the capital-gains addition was deleted.

Unexplained-investment addition under Section 69 could not be sustained where the cash-payment computation incorrectly treated the stated total purchase cost as consideration paid in addition to the registered value, available funds explained the actual cash payments, and no corroborative evidence established unexplained investment. Rural agricultural land was not a capital asset for capital-gains purposes where, for Assessment Year 2011-12, distance had to be measured from municipal limits existing on the relevant notification date rather than subsequently expanded limits. Diversion of land at the purchaser's request did not alter its agricultural character for the transaction. Consequently, no taxable unexplained investment or capital gain arose.

Suo motu disallowance of expenditure for failure to deduct tax does not extinguish the separate obligation to deduct and deposit tax under the tax-deduction regime, nor does it preclude consequences for default. Liability concerning year-end expense provisions depends on verified facts rather than aggregate tax-audit disclosures. Relevant verification includes whether provisions identify particular vendors and credited amounts, whether liabilities arise from estimates or invoices, whether entries were reversed, and whether tax was deducted when invoices were received. Deletion of tax and interest demands requires examination of these vendor-wise provisions and subsequent tax-deduction compliance.

Compensation received by BSNL employees under the BSNL Voluntary Retirement Scheme, 2019 is characterised in substance as retrenchment compensation rather than voluntary-retirement compensation taxable beyond the separate statutory exemption. On that characterisation, the payment constitutes a capital receipt and is exempt from income tax under Section 10(10B) of the Income-tax Act, 1961. The treatment follows coordinate decisions addressing the same scheme compensation.

Reassessment jurisdiction requires a valid statutory notice, clear and specific jurisdictional satisfaction, and approval showing independent scrutiny. Omnibus notices that retain mutually inapplicable contingencies without identifying the relevant search, documents, or alleged income fail to establish jurisdiction. A reassessment cannot materially depart from the recorded satisfaction by adopting a different basis for taxing the transaction. Where reliance is placed on third-party material or statements, the affected person must receive the underlying material and an effective opportunity for cross-examination when specifically requested. Defective notice, vague satisfaction, mechanical approval, and denial of procedural fairness render the reassessment proceedings and resulting order void from inception.

Foreign withholding taxes eligible for double-taxation relief under sections 90 or 91 fall within Explanation 1 to section 40(a)(ii), even when nil Indian tax liability prevents use of the foreign tax credit. Such taxes therefore cannot be claimed as business expenditure under section 37(1). An additional claim for that deduction may be examined in appellate proceedings where foreign-source income, taxes paid and credit claimed were already disclosed in the return, computation and Form 67, so that no further fact-finding is required; Rule 46A does not warrant threshold rejection. Eligibility for relief, rather than actual credit utilisation, determines the deduction bar.

Deletion of an addition for alleged unexplained expenditure is justified where the taxpayer substantiates purchases through invoices, ledger accounts, bank-payment records, supplier confirmations, transport documents, e-way bills, bill-T receipts and supplier GST returns. Differences between books and GST data require reconciliation, including whether book figures are GST-inclusive and GST figures GST-exclusive. Non-response by suppliers to information notices alone does not warrant an adverse inference when the taxpayer's evidence is unrebutted. Unexplained-expenditure provisions apply only where the source of expenditure remains unproved; documented banking-channel payments establish that source.

Trade and quantity discounts earned by a dairy resale agent were explained receipts where bank records showed a joint account with the dairy, same-day deposit and withdrawal of sales proceeds by the dairy, and agency income limited to discounts. Treating those discounts as unexplained money and estimating taxable income by allowing only a portion as storage and distribution expenses lacked justification. The estimated addition was deleted.

Transfer-pricing analysis treats enterprises as associated where an overseas entity's business is wholly dependent on regulatory affairs and compliance processes performed by the Indian entity, engaging section 92A(2)(g). The Indian entity remains the tested party where foreign comparable data cannot be readily accessed or verified. Regulatory affairs services cannot be re-characterised as knowledge process outsourcing unless they fall within Rule 10TA(g)'s exhaustive definition. Comparables performing materially different functions fail functional, asset and risk and comparability analysis; the arm's length price requires fresh benchmarking against functionally comparable entities after an opportunity to furnish relevant material.

Penalty for furnishing inaccurate particulars does not arise where capital-gains computation on a slump sale, including treatment of negative net worth, rests on a bona fide and fully disclosed legal claim. Divergent Tribunal interpretations of the relevant provision and admission of a substantial question of law demonstrated that the issue was debatable. Acceptance of a quantum addition, including by not pursuing a ground to avoid further litigation, does not by itself establish concealment or inaccurate particulars. Penalty was therefore not leviable, and its deletion was sustained.

Section 270A distinguishes under-reporting, penalised at 50% of tax on under-reported income, from misreporting, which attracts 200% only where the specified statutory circumstances are proved. Omitted interest income and its detection by the Revenue establish under-reporting but do not automatically establish misreporting; enhanced penalty requires independent evidence of the relevant statutory ingredients. Non-response to electronic notices alone is insufficient for that characterisation. Multiple reassessment, show-cause and penalty-stage notices may satisfy the opportunity-of-hearing requirement where the taxpayer does not use the available opportunities.

Corpus treatment for infrastructure grants may be established through donor resolutions, earmarking, separate fund accounting and use for the specified infrastructure purpose; a separate written direction for each contribution is not necessary. Charitable entities may claim permitted statutory accumulation and, where applicable, accumulation despite delayed filing of the prescribed form when condonation relief applies. Additions for alleged double application require prior notice and an opportunity to respond. Promotion of cricket does not constitute trade, commerce or business without evidence of commercial operations. Depreciation cannot be denied without proof that asset cost was previously claimed as application, while additions for prohibited benefits and enhanced receipts require identified violations and evidentiary support.