Limitation for a customs appeal runs from proven service of the adjudication order; where Revenue cannot establish earlier service and the appellant files within the statutory period after receiving an RTI copy, dismissal as time-barred is erroneous. For unmarked gold carried openly by a domestic passenger, Revenue must establish foreign origin before the burden under Section 123 arises. A retracted statement without independent corroboration, absent foreign markings and without characteristics of standard foreign gold, does not meet that burden. Domestic travel creates no international baggage-declaration obligation. Confiscation and penalty under Sections 111(l) and 111(m) were therefore set aside, with consequential relief.

Statutory pre-deposit in a customs appeal is a curable defect where the appeal is filed within limitation; the bar applies to entertaining the appeal on merits, not to its presentation. Dismissal without notifying the deficiency and providing a hearing is unsustainable, although separate pre-deposit requirements apply at each appellate stage. Recovery proceedings for alleged erroneous Special Additional Duty refunds may be initiated while review or departmental appeals are pending, but recovery founded solely on appellate orders cannot survive once those orders are set aside or recalled and refund entitlement attains finality. Remand is unnecessary where it would merely implement binding final orders; the dismissal and consequential recovery demands were set aside.

The proviso to Section 129A excludes Tribunal jurisdiction over appeals from Commissioner (Appeals) orders relating to goods imported or exported as baggage. Baggage describes the mode and category of import, and goods retain that character regardless of whether they are dutiable, prohibited, confiscable, bona fide or non-bona fide. Gold articles carried into India by arriving passengers and dealt with as baggage therefore fall within the exclusion. Challenges to confiscation and penalties concerning such gold articles must be pursued through revision before the Revisional Authority under Section 129DD, rather than before the Tribunal.

SFIO investigation orders made in the public interest must be founded on demonstrable, relevant circumstances. Judicial review examines whether the statutory decision-making process was flawed, rather than reassessing the adequacy or propriety of the underlying material. Detailed grounds need not be disclosed where disclosure could prejudice public interest or the investigation. Quashing of an FIR following settlement of homebuyer complaints does not resolve separate allegations of false loan documentation and diversion of company funds. The High Court found that the investigation order and its stated scope showed due consideration of those distinct allegations, sustained the order, and dismissed the writ application.

Res judicata prevents reopening a compulsory share-buyout valuation once prior appellate proceedings have confirmed the valuation mechanism and report, following opportunities for submissions before the valuer and adjudicating authority. Liberty to seek further directions is confined to enforcing the earlier order and does not authorise a renewed valuation challenge. Merger principles associated with dismissal of a special-leave petition do not apply to this special statutory appellate jurisdiction. An application for rectification and fresh valuation is therefore not maintainable because it reopens a concluded issue and constitutes abuse of process; rejection of the application and dismissal of the appeal follow.

FERA liabilities, penalties and legal remedies remain preserved after repeal through FEMA's saving scheme, read with the General Clauses Act, so that prior contraventions continue to be dealt with as though FERA remained in force. The appellate route under FEMA does not recharacterise saved FERA penalty adjudications as civil revenue litigation. Appeals from FERA-based penalties are therefore maintainable in criminal appellate jurisdiction, and objections that they must proceed only on the Original Side do not apply.

The first proviso to Section 45(1) of the PMLA addresses an exception to the statutory twin bail conditions for women accused of money laundering. Relevant considerations include prolonged custody, setting aside of an earlier cognizance order, extensive material and witnesses, continuing investigations into scheduled offences, and whether the trial is likely to conclude soon. Where those circumstances indicate that timely completion of trial is unlikely, continued pre-trial incarceration warrants scrutiny when considering regular bail.

Prosecution for possession of assets disproportionate to known lawful income requires proof of the public servant's known income, assets, pecuniary resources and expenditure during the relevant check period; it need not undertake a roving inquiry into undisclosed income. Once substantial disproportion is shown, the public servant must provide a satisfactory, credible and verifiable explanation because asset sources and acquisition are within that person's special knowledge. Unsupported challenges to asset valuation, household expenditure and claimed income did not rebut the established disproportion, so the conviction for criminal misconduct was affirmed.

Extended limitation for service-tax recovery under the proviso to Section 73(1) requires specific pleading and proof of fraud, wilful misstatement, suppression of facts, or contravention committed with intent to evade tax. Revenue bears the burden of establishing such mala fide conduct. Non-collection of service tax, coupled with a bona fide belief that works-contract services were exempt, does not by itself demonstrate deliberate intent to evade. Where the available material does not establish the required intent, the extended period cannot support recovery and the demand is barred by limitation.

Appeals concerning baggage imported under the Customs Act, 1962 and the Baggage Rules, 1998 fall within the Central Government's revisionary jurisdiction rather than the Tribunal's appellate jurisdiction. An appeal on such baggage matters is therefore not maintainable before the Tribunal. The prescribed remedy is a revision application to the Central Government under the Customs Act.

Transfer-pricing analysis under the Transactional Net Margin Method requires turnover and functional comparability: high-turnover, diversified, product-based, or otherwise functionally distinct entities should be excluded, and working-capital adjustments calculated from actual data should not be arbitrarily capped. A timely reference to the Transfer Pricing Officer triggers the extended assessment limitation period. For Section 10A, expenditure excluded from export turnover must also be excluded from total turnover, and the deduction is computed undertaking-wise before gross-total-income reductions, subject to verification of relevant figures. Employee misappropriation incidental to business may be deductible in the year discovered, subject to evaluation of recovery evidence and consequential adjustment to eligible undertaking profits.

Where a property purchaser disputes the stamp-duty valuation used to compute the taxable consideration difference under Section 56(2)(x)(b), a Departmental Valuation Officer's valuation is required before that difference is adjudicated for income-tax purposes. The assessment must be reconsidered on the Departmental Valuation Officer's valuation, and the assessee must substantiate its position during the fresh proceedings.

Eligibility for deduction under Section 80P required factual verification because the statutory audit report in Form 3CA/3CD was produced before the Tribunal rather than before the lower authorities. Although the return was treated as timely filed in light of the audit requirement, the report's verification and its effect on deduction eligibility required examination. The deduction claim was remitted to the Assessing Officer for fresh adjudication after providing the assessee an opportunity, without a final determination on eligibility.

Section 151 approval for reassessment must demonstrate the approving authority's independent application of mind through recorded satisfaction. A same-day online endorsement stating only "approved", without reasons or discernible satisfaction, constitutes mechanical sanction and does not support valid assumption of jurisdiction under Sections 147 and 148; the reopening proceedings consequently fail. Section 253(5) permits condonation where sufficient cause is established: an inadvertent, non-malafide filing oversight supported by affidavit justified condonation of the delay in filing the appeal.

Penalty for non-compliance with a statutory notice requires actual defiance. A written response received before the stipulated hearing date constitutes compliance, even where it challenges the jurisdictional basis of the proceedings. Non-filing differs from filing a response that the Assessing Officer considers unsatisfactory; dissatisfaction with the response cannot establish default. Because the response was received but not considered before the penalty was imposed, the alleged non-compliance was unproved, rendering the penalty unsustainable and requiring the penalty orders to be quashed.

The Income-tax Act permits penalties for failure to comply with scrutiny notices. In faceless assessments, notices are served electronically, and communication gaps may prevent effective compliance. Non-compliance attributable to circumstances beyond the taxpayer's control may therefore be justified rather than treated as deliberate non-cooperation. On that basis, the penalty for failure to respond to scrutiny notices was deleted.

Assessment proceedings under Section 144 cannot be sustained against a company struck off from the register before the assessment was framed where the proceedings themselves commenced after strike-off. Governing precedent treats the company's removal from the register as preventing continuation of the assessment mechanism, with the resulting assessment liable to be quashed.

For assessment year 2018-19, exemption under Section 10(23C)(iiiad) applied by testing the annual receipts of each educational institution separately. Receipts of multiple institutions run by the same society could not be aggregated merely because their collective receipts exceeded the prescribed limit. The later amendment effective from 1 April 2022, which requires aggregation at the level of the person running multiple institutions, did not apply to that assessment year. Each institution remaining below the prescribed limit therefore qualified for exemption.

Reassessment jurisdiction under Sections 147 and 148 requires recorded reasons based on correct and verified foundational facts. A recorded premise that no return was filed is unsustainable where the return, its acknowledgement, and a refund issued on its basis are already on record. Making a cash-deposit addition without considering returned income further demonstrates non-application of mind. On these facts, the reassessment notice, consequential proceedings, and best-judgment assessment were void ab initio for invalid assumption of jurisdiction.

Search-based assessment founded entirely on material seized from another person falls within the special regime under Sections 153A and 153C, which overrides regular reassessment under Sections 147 and 148. Where seized material belongs or relates to a person other than the searched person, proceedings must be initiated under Section 153C after its statutory conditions are met. Sections 147 and 148 remain available for regular reassessment and matters not based on incriminating search material. Without distinct material outside the search, reopening under Sections 147 and 148 is legally untenable.