Section 123 of the Customs Act places a reverse burden for notified gold only where seizure rests on an objectively founded reasonable belief of smuggling. Suspicion, high purity and generic fineness markings do not by themselves establish foreign origin or unlawful importation, particularly where domestic invoices, supplier confirmation and banking records remain unrebutted. Retracted statements require reliable independent corroboration, and discrepancies in seizure evidence weaken their probative value. Where supplier or Panch witness statements prove disputed facts, denial of cross-examination reduces their evidentiary weight unless statutory conditions permit reliance without it. Confiscation and related penalties require proof of unlawful importation or contravention, together with requisite knowledge for penal liability.

For notified gold, the reverse burden arises only where seizure rests on an objectively sustainable reasonable belief of smuggling; suspicion, generic fineness markings and unverified assertions of foreign origin are insufficient. Credible domestic-procurement evidence, including matching invoices, supplier confirmation, GST particulars and banking payment, may discharge the burden where unrebutted by investigation. Promptly retracted statements require independent corroboration and assessment of voluntariness before supporting confiscation. Where such statements prove disputed material facts, denial of effective cross-examination prejudices the affected party and weakens their evidentiary value. Without proof of unlawful importation, consequential confiscation of related goods and penalties requiring knowledge cannot be sustained.

Presumption of smuggling for seized gold arises only when reasonable belief rests on objective material connecting the particular gold to illicit importation. Re-melted gold found domestically, without foreign markings, a traceable foreign source, or evidence of an illicit import route, does not establish foreign origin. Unexplained inconsistencies between FASTag records and the Panchanama, uncorroborated retracted statements, and denial of cross-examination undermine the evidentiary basis. Pre-existing tax invoices, supplier confirmation, and banking records support domestic acquisition. Confiscation under Sections 111(d) and 111(o) was not established, and consequential penalties under Sections 112(a) and 112(b) could not survive.

Section 14 of the Limitation Act, 1963 permits exclusion of time spent bona fide pursuing a remedy before a forum believed to have jurisdiction. Time spent in writ and special leave proceedings may therefore be excluded where the challenge was prosecuted honestly, although the appellate remedy lay before the Tribunal. The residual delay may be condoned under Section 5 where sufficiently explained, applying a liberal, justice-oriented approach that favours substantial justice over technical rejection on limitation. Costs may be imposed while condoning the remaining delay.

Written acceptance of an enhanced customs value waives only the requirement for a speaking reassessment order under Section 17(5) of the Customs Act; it does not remove the statutory right to appeal reassessment. Rejecting a declared transaction value requires compliance with Section 14 and Rule 12(2) of the Customs Valuation Rules, including written grounds for doubting that value. Any redetermination must then follow the sequential valuation rules. General references to contemporaneous-import data, without disclosure of comparable data, do not establish voluntary and unconditional abandonment of the right to challenge valuation. Consent or acquiescence cannot override statutory valuation safeguards or appellate rights.

Goods declared in import documentation that accompany or facilitate concealment of undeclared imports are liable to confiscation under the Customs Act. Where confiscated goods are released on redemption, redemption fine remains applicable but must be proportionate to their declared and assessed value. Unexplained undeclared goods, material misdeclaration of quantity, description or value, and lack of contemporaneous purchase or payment records support penalties for improper importation. Penalty for acts rendering goods liable to confiscation may arise under Section 112(a) without separately proving that the person had reason to believe the goods were confiscable, unlike Section 112(b). Monetary fines and penalties must nevertheless remain proportionate.

Rejection of declared transaction value and redetermination of customs value require material showing an untrue importer declaration; a supplier's bona fide shipment of incorrect goods, without evidence of importer misdeclaration, suppression or intent to evade duty, does not justify enhancement or consequential duty demand. Confiscation and penalty likewise cannot rest solely on the supplier's error. Packaged-commodity labelling declarations may be affixed with permission before home-consumption clearance, making the deficiency curable. Goods lacking mandatory BIS compliance remain subject to re-export where the foreign supplier lacks the required registration; related redemption fine concerning those goods remains unaffected.

Adjustment of a Special Additional Duty refund against a duty drawback demand that remains capable of challenge is impermissible because only final recoverable arrears may be adjusted under section 142(a) of the Customs Act, 1962. Where fresh adjudication subsequently drops the drawback demand, the retained refund must be released to the assessee. Applicable interest on the refund is payable in accordance with law.

Rule 11UA recognises the Discounted Cash Flow method for valuing shares under Section 56(2)(viib). Valuation based on projected future performance should not be rejected by substituting actual subsequent results or the Net Asset Value method, where the taxpayer has adopted a prescribed method. Interest on borrowings used to construct commercial buildings may remain deductible as revenue expenditure under Section 36(1)(iii) where the buildings generate business income; a later occupancy certificate does not by itself establish that the buildings were not put to business use. Advertisement and marketing expenditure for operational commercial space may be deductible under Section 37(1), as the occupancy certificate alone does not determine commercial readiness or business-purpose deductibility.

Registration under sections 12AB and 80G(5) cannot be refused solely because an applicant lacks registration under the Rajasthan Public Trust Act, 1959, without first deciding whether the statutory exclusion for trusts administered by an agency under State Government or local-authority control applies. Governmental control required examination of the arrangement with a Government medical institution, Government representation on the management committee, prescribed supervision, and no-profit-no-loss operations. Absence of Government grants, private trusteeship, or subsidised user charges was not conclusive. No finding established non-charitable objects or non-genuine activities; accordingly, the issue was resolved in favour of the assessee.

Valuation and cost-of-acquisition grounds required a reasoned adjudication after a reasonable hearing because they had not been adequately addressed. The appellate order was set aside and the appeal restored for fresh disposal on merits. Any additional evidence must be considered under the procedure governing its admission at the appellate stage in law.

Depreciation remained available under the block-of-assets regime where the dry plant continued in use, and was also allowable for specified commercial vehicles, qualifying generators and amalgamation goodwill. Exempt-income disallowance excluded interest where interest-free funds exceeded investments; administrative expenditure required restricted recomputation. Demurrage reducing FOB sale consideration, irrecoverable trading advances, road and afforestation payments, lease-renewal stamp duty, dumping charges, obsolete stock, and vessel repairs were treated as deductible revenue items. A retrospective amendment did not create a past withholding obligation for overseas services not then taxable. Unsupported cash-receipt addition was deleted; only limited disallowances remained for community expenditure and foreign travel.

Operational expenditure incurred to run, maintain and improve an existing telecom network remains revenue expenditure where it lacks a demonstrated nexus with creating or acquiring a capital asset, notwithstanding its allocation to capital work-in-progress in the accounts. Its deduction is governed by its real tax character rather than book presentation. Payments to non-resident telecom operators for connectivity, voice termination, bandwidth, and operation-and-maintenance services are not royalty or fees for technical services where the payer receives no right to use equipment or processes and no technical capability is made available. In the absence of a permanent establishment, such payments are not taxable as business profits in India, removing withholding and related disallowance exposure.

Foreign Tax Credit under section 90 is substantive relief against double taxation, while Form No. 67 under Rule 128(9) serves a procedural function by providing implementation particulars. Delay in furnishing the form does not carry a prescribed forfeiture of an otherwise admissible credit, and the later extension of the filing time supports this procedural character. The administrative condonation mechanism under section 119(2)(b) does not restrict appellate relief where substantive eligibility is established. Foreign-tax payment must be verified, following which admissible credit should be allowed without requiring separate condonation solely for delayed Form No. 67.

Deeming additions under sections 68, 69 and 69A require proof of the relevant statutory facts during the relevant year. A corrected opening capital balance traceable to an accepted prior-year closing balance is not current-year income without a fresh unexplained accretion. Section 69A cannot apply without evidence linking the taxpayer to unexplained money. Section 68 requires a credit during the year and does not cover brought-forward balances or explained contractual liabilities; recorded sundry debtors are debit balances, not unexplained credits or unrecorded investments. On these principles, additions for capital variation, alleged property on-money, creditors and debtors were deleted.

Section 10AA deduction claims require fresh verification where compliance with Form 56F requirements and supporting evidence have not been examined by the Assessing Officer. Earlier directions to consider a manually filed Form 56F, having attained finality, cannot be reopened in subsequent proceedings. In the absence of compliance before the Assessing Officer and without a remand report before the appellate authority, the deduction claim requires fresh merits adjudication. The matters stand remitted to the Assessing Officer for verification and adjudication.

For assessment limitation under section 153, the relevant date is when the order is made or passed, not its dispatch, communication or receipt, unless material proves it was made later. Differences between rental income in Form 26AS and the books require reconciliation of lease terms, accounting recognition, tax deduction timing and prior or subsequent years before any addition is made. Interest on a refinancing borrowing may qualify for deduction under section 24(b) where it exclusively repays an original property acquisition or construction loan and a direct borrowing nexus is verified. An alternative business-interest claim may require consideration where applicable.

Interest-free, repayable housing assistance to genuinely financially needy persons may qualify as relief of the poor and therefore as charitable activity. This limb of charitable purpose operates independently of general public utility and does not require outright grants or beneficiaries with no income. Repayment obligations, recovery safeguards, monitoring, scale of operations and redeployment of recovered funds do not alone make the scheme a money-lending or micro-finance business where no interest, fee, commission, mark-up or commercial return is earned. Registration eligibility requires verification of beneficiary need, loan terms, absence of commercial return and recycling of recoveries; registration should follow if these conditions are met. Unsupported allegations of non-compliant investments cannot justify rejection.

Cash deposits supported by undisputed ownership and cultivation of agricultural land, landholding records, monthly sale summaries, and Agricultural Produce Market Committee sale bills constituted evidence of agricultural income. Omission of crop particulars from revenue records, lack of seed and pesticide purchase vouchers in small-scale farming, and non-reporting of exempt agricultural income in other returns did not undermine that evidence without independent verification or contrary material. The deposits therefore could not be treated as unexplained money under Section 69A of the Income-tax Act, 1961.

Foreign Tax Credit cannot be denied solely because Form No. 67 was furnished after the return-filing due date where foreign income was disclosed and foreign tax payment is verifiable. Rule 128(9) prescribes the filing timeline but does not attach denial of credit to delay, while section 90 imposes no such time limit and Rule 128(4) identifies the circumstances for denial. The timing requirement is therefore directory and cannot defeat substantive relief from double taxation. The later permission to furnish Form No. 67 until the end of the assessment year supports allowing the credit despite delayed filing.