Declared transaction value for imported cigarettes cannot be rejected or enhanced merely on unauthenticated certificates of origin and purported export shipping bills. A valid overseas supply contract supported the declared value, while no evidence established additional payment, misclassification, or higher-priced comparable imports. The certificate was neither used for preferential treatment nor officially verified, and third-party shipping bills were not shown to be authentic or to reflect the true import price. Uncorroborated statements acknowledging those documents were insufficient without admissible supporting evidence. In the absence of reliable contemporaneous import evidence or cogent valuation material, the undervaluation allegation fails.

Penalty under Section 112(b) requires proof that the person knew the imported goods were offending goods. Uncorroborated customs broker statements, a non-inculpatory statement by the person penalised, and the absence of evidence from the person seeking temporary storage did not establish that knowledge. Although the imported goods were stored other than at the designated place without informing customs authorities, that breach did not satisfy the knowledge requirement for Section 112(b). The conduct instead attracted the residual penalty under Section 117 for failure to comply with storage-related customs requirements.

Preferential customs-duty benefits require Customs to follow the prescribed verification process before rejecting a Certificate of Origin. Where Customs doubts a certificate, it must communicate the grounds to the issuing authority and obtain clarification through specific, time-bound verification. General communications concerning other certificates or importers do not establish that an importer's certificate is non-authentic. Documentary certificates cannot be displaced by assumptions about a supplier's business profile, unverified electronic communications, or third-party statements. Retracted and uncorroborated statements, particularly where not tested through examination and cross-examination, cannot substitute for verification. Failure to undertake certificate-specific verification renders denial of preferential duty and consequential recovery, confiscation, fine and penalties unsustainable.

Keyboards imported through courier for personal use remain classifiable under Customs Tariff Heading 8471 60 40 where that specific entry carries a free rate of duty. Chapter 98 overrides a specific tariff heading only when its conditions are met. Heading 9804 and the corresponding Schedule IV IGST entry apply only to dutiable goods imported for personal use; goods attracting no duty under their applicable tariff entry are not dutiable goods. Consequently, keyboards covered by the free-rate Heading 8471 60 40 cannot be reclassified under Heading 9804, and customs duty or IGST under that personal-import entry does not apply.

Aluminium hollow profiles retain classification under the specific tariff heading for aluminium profiles where their objective characteristics, including uniform cross-section, remain intact at import. Cutting profiles to length, invoice descriptions, prior self-assessment and intended use in solar modules do not by themselves convert them into finished articles or justify classification under a residuary heading. Concessional customs treatment for Chapter 76 goods used to manufacture notified Solar PV Modules depends on the prescribed end-use procedure and valid end-use certificates, rather than possible alternative uses or precise classification within that Chapter. The stated amendment applies prospectively from 1 April 2022; concessional treatment remains available for earlier Bills of Entry meeting the conditions.

Redemption of confiscated foreign currency under Section 125 of the Customs Act is discretionary where the currency was exported without declaration or required permission and may be treated as prohibited goods. That discretion must be exercised judiciously on the facts, rather than refused mechanically because the goods are prohibited. Relevant considerations include the absence of earlier Customs Act violations, payment of penalty, the statutory limit on redemption fine, and consistency with comparable cases. Refusal of redemption was set aside, requiring release of the currency upon payment of a redemption fine determined under Section 125.

Retrospective amendments to the Foreign Trade Policy cannot extinguish Service Exports from India Scheme benefits accrued by exporters for eligible services already rendered and foreign exchange already earned. Section 5 of the Foreign Trade (Development and Regulation) Act, 1992 permits formulation and amendment of the policy but does not authorise retrospective curtailment of accrued scheme entitlements. Notifications introducing Appendix 3X, excluding specified services and imposing a cap for FY 2019-20 operate only from their respective issue dates. Exporters remain entitled to SEIS benefits accrued during the relevant pre-notification period.

Benami classification under Section 2(9)(C) requires that the ostensible owner be unaware of, or deny knowledge of, the property ownership. Job workers acknowledged during cross-examination that they knew of the share allotment, buy-back and consideration credited to their bank accounts. These statements outweighed inconsistent earlier income-tax statements. Allegations of fictitious trade payables or tax evasion could not independently establish a benami transaction without satisfying the statutory knowledge requirement. The income-tax settlement order did not override the separate benami regime. The share transactions therefore fell outside Section 2(9)(C), and refusal to confirm provisional attachment was sustained.

Tax deduction under section 194LBC applies only to income payable to an investor in respect of that investor's investment in a securitisation trust. Excess Interest Spread paid to an originator that neither subscribed to pass-through certificates nor otherwise invested in the trust does not meet those conditions. Maintaining the minimum retention requirement through cash collateral does not make the originator an investor for this purpose. As the payment represents residual surplus under the transaction waterfall rather than income from an investment, no tax is deductible under section 194LBC, and default consequences under sections 201(1) and 201(1A) do not arise.

Interest awarded under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsorily acquired land is treated as an accretion to the land's value and forms part of enhanced compensation. It differs from interest under Section 34, which compensates for delayed payment. Income-tax amendments governing interest on compensation address the timing of taxation of interest income and do not change the character of Section 28 interest. Accordingly, Section 28 interest is not assessable under the head Income from Other Sources.

Notice under Section 143(2) is not required for reassessment where no valid return is filed under Section 139 or in response to a notice under Section 148. Exemption under Section 10(26) applies only to qualifying income computed under the Act, not to gross receipts or bank deposits; tribal status, residence documentation and GST registration alone do not establish eligible business income. Cash deposits may be assessed as unexplained money under Section 69A where the taxpayer fails to substantiate their nature and source with reliable business records, books of account, bills, vouchers or financial statements.

Foreign-currency loans to associated enterprises may be benchmarked under the Comparable Uncontrolled Price method using foreign lending rates and external comparable borrowings; a domestic cost-of-funds approach is not a comparable uncontrolled price for an international loan. Interest charged at LIBOR plus 350 basis points was treated as arm's length. A standby letter of credit for an associated enterprise's borrowing requires arm's length benchmarking, with the corporate-guarantee benchmark restricted to 0.5% absent material supporting a higher fee. Weighted deduction for eligible expenditure on a DSIR-approved in-house research and development facility is not limited to the amount quantified in Form 3CL.

Transactional net margin method comparables for captive data-processing and software-development services must be functionally and economically similar. Rule 10B(4) permits use of data from the two preceding years; a company is not a persistent loss-maker merely because it incurred losses in some relevant years, and a differing accounting year alone does not require exclusion where quarterly data can be extrapolated. Companies with materially different business models, substantial outsourcing, high-end services, software products, diversified licensing activities, significant brands or intangibles, entrepreneurial scale, or unreliable segmental data should be excluded. Repair and maintenance provisions require verification of supporting evidence, subsequent crystallisation and reversal, consistent with DRP directions.

Corporate charges paid to a Singapore group entity for managerial, administrative, marketing and business-support services were not chargeable to tax in India. The services did not make available technical knowledge, experience, skill, know-how or processes for the payer's independent future use and therefore were not fees for technical services under the India-Singapore tax treaty. No cogent material established either a fixed place or dependent-agent permanent establishment in India, so the recipient's business profits were not taxable in India. The more beneficial treaty provisions prevailed over domestic law; accordingly, no tax-withholding obligation or related disallowance arose.

IPL franchise rights that confer exclusive commercial rights to own and operate a franchise, participate in the league and exploit related revenue streams constitute depreciable intangible business or commercial rights. Their actual cost is the full contractual consideration when liability arises on acquisition; deferred instalments are only a payment mode, subject to written-down-value adjustment if consideration is later altered. Transfer-pricing review must test arm's-length consideration and cannot question the commercial expediency, necessity or adequacy of services. Management-fee reimbursement requires fresh determination on supporting evidence rather than a nil value. Where aggregate international transactions exceed the prescribed threshold, a binding CBDT Instruction requires reference to the Transfer Pricing Officer; an internal action plan cannot alter that requirement.

Appellate authorities may condone delayed appeals and entertain a legally available exemption claim even where the return cited an incorrect provision and no adjustment arose in the processing intimation. Compensation paid to BSNL employees under the Voluntary Retirement Scheme, 2019 is treated as retrenchment compensation eligible for exemption under Section 10(10B), reflecting the scheme's workforce-reduction purpose. Eligible retired employees are also treated as deemed Central Government employees for leave-encashment exemption under Section 10(10AA); the enhanced beneficial exemption limit applies in appellate proceedings. These principles support substantive relief based on the correct statutory exemption rather than the original characterisation of the claim.

Offshore sales by a non-resident to an Indian affiliate or customers are not taxable in India where contracts are concluded and title and risk pass outside India, and no sales-related operations are undertaken in India. Under the business-connection rule, only income attributable to Indian operations may be taxed. An Indian affiliate does not create a fixed-place permanent establishment unless its premises are at the foreign enterprise's disposal, and does not create an agency permanent establishment without authority to conclude contracts, habitually secure orders, or maintain stock for delivery. In the absence of a business connection or permanent establishment, no business profits are attributable to India under the treaty.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer has examined unsecured loans, obtained supporting material and adopted a plausible view, revision cannot rest merely on a preference for further inquiry or a different view; inadequate inquiry alone is insufficient. For alleged suppression of business receipts, the revisional authority must conduct necessary independent inquiry and identify defects in the assessee's reconciliation before directing fresh examination. Without a definite finding of error and prejudice, revision becomes an impermissible fishing or roving inquiry. The stated revision grounds were therefore invalid.

Overseas NRI Desk costs for internal audit, financial control, information technology, human resources, operations, rent, maintenance, depreciation and advertising are characterised as executive and general administration expenses of overseas banking operations. Although connected with Indian business operations, such costs fall within the specified categories of head office expenditure rather than direct business expenditure. Their deduction is therefore restricted to the statutory ceiling applicable to head office expenditure and cannot be claimed in full.

Cash-method accounting permits interest and dividend income to be taxed only on actual receipt where that method has been consistently followed; rejection of books does not justify presumed accrual. Unsupported additions for money-market and share-market oversold positions, trading profits, assumed interest, and estimated income fail where delivery, ownership, receipt, or third-party evidence is not established and documentary explanations remain unrebutted. Disclosed banking transactions cannot be treated as unexplained without substantiated contrary material, while bank credits remain taxable where their nature and source are not explained. Opening balances of loans and advances are not assessable in the relevant year; remaining balances require verification. Assessed income may be telescoped against unexplained investment or expenditure, subject to consequential computation and statutory relief.