Corporate amalgamation required substitution of the appellant's name in the service-tax appeal cause title, from the predecessor company to the amalgamated company. Supporting documents were filed to establish the change in corporate identity. The registry was directed to amend the cause title so that the pending proceedings reflect the successor entity's current name.

Indexed cost of improvement in computing capital gains requires supporting evidence of the expenditure. Passage of time does not remove the taxpayer's obligation to substantiate a claimed improvement cost. Where no evidence supports the claim, the indexed cost of improvement is not allowable and is disallowed in computing capital gains.

Interest earned by a primary credit co-operative society on deposits with co-operative, scheduled and nationalised banks qualifies for deduction under sections 80P(2)(a)(i) and 80P(2)(d), where the relevant statutory conditions are met. The treatment applies to interest income arising from deposits held with both co-operative and other banking institutions. Interest received on an income-tax refund is also included within the deduction available under section 80P(2)(c)(ii). The deductions claimed under these respective provisions are consequently available to the society.

Cash deposits arising from the sale of rural agricultural land were satisfactorily explained by registered sale records, the sale agreement, cash received instead of the cheque recorded in the sale deed, and additional sale consideration. As the land was not a capital asset and sale income was exempt, the stated sale proceeds constituted an acceptable source for both deposits. No addition as unexplained money was sustainable where the Revenue did not dispute the land's rural agricultural character or the exempt nature of the sale income.

Government securities held by banks are treated as stock-in-trade, so diminution in their value, when recorded under banking norms, is allowable as revenue expenditure. An additional depreciation claim raised during assessment may be determined from material already on record. Mutual-fund dividend income is exempt where a revised computation and supporting evidence establish its receipt and no factual rebuttal arises. Taxable income is consequently recomputed after allowing the securities depreciation and exempt-dividend claims.

Penalty for concealment under Section 271(1)(c) cannot survive where it is founded on an unexplained cash-deposit addition that has been deleted in quantum proceedings. The penalty attributable to that deleted addition was therefore removed. However, where an interest-income addition remained unchallenged in the quantum appeal, the penalty corresponding to that undisclosed income remained sustainable.

Rectification under Section 154 is unavailable where interest income was declared in the return and accepted in assessment, unless the assessment order itself contains an apparent mistake. An alleged error in the return does not by itself establish a rectifiable error in the assessment. A non-speaking appellate dismissal arising from non-compliance requires fresh, reasoned adjudication where the taxpayer must receive a reasonable opportunity to substantiate the claim that income was inadvertently offered to tax. The substantive taxability claim therefore remains open for appellate consideration on supporting material.

Deduction for an approved industrial park under Section 80IA(4)(iii) remained available because the Central Government's Empowered Committee had not withdrawn its original approval and compliance with the approved conditions was established. Rule 18C places approval and compliance examination with the Central Government; CBDT's role after approval is limited to notifying the industrial park. CBDT therefore lacked statutory authority to retrospectively rescind its notification while the underlying approval continued. The undertaking was entitled to the deduction for the relevant assessment years.

Covid-related delay in filing a first appeal may constitute bona fide and reasonable cause for condonation where the effective delay is not inordinate. For non-compliance with statutory notices, an assessment completed after the assessee furnished an explanation, even if unsatisfactory, indicates participation rather than total non-appearance. In those circumstances, penalties for repeated defaults may be confined to the initial default instead of being imposed separately for each notice, resulting in substantial reduction of the non-compliance penalty.

Cash found at a taxpayer's residence cannot be treated as unexplained money in that taxpayer's hands when evidence establishes ownership by another taxpayer. Cash-balance details and income-tax returns showing sufficient disclosed cash-in-hand of family members independently conducting business supported attribution of the cash to joint-family business proceeds. Co-residence within a joint family did not, by itself, establish that the cash belonged to the taxpayer. On those facts, the unexplained-money addition under Section 69A was unjustified and deleted.

For completed or unabated assessments, additions under section 153A require incriminating material found during the search. Third-party email backups, bank-payment analysis and statements did not independently establish unaccounted sales where no cogent or corroborative evidence was found at the assessee's premises. Post-search compilations did not constitute seized incriminating material, and selective reliance on unsupported statements could not sustain additions for alleged suppressed sales. The additions for the relevant assessment years were therefore deleted.

Peak-credit computation of seized finance-business notebooks treats undisclosed receipts and outgoings as business income where no separate non-business source is established. Section 69 deeming treatment for unexplained investment does not apply to the peak amount in those circumstances. Interest, commission and miscellaneous receipts already included in the peak-credit working cannot be separately added while retaining that computation, because this would tax the same income twice. Where excluding those receipts eliminates the peak credit, undisclosed finance-business receipts remain taxable only through the sustained peak-credit business-income computation.

Section 80P deduction cannot be disallowed solely through a computation sheet where the assessment order, on the same limited-scrutiny issue, expressly records that no addition was made. Although a computation sheet forms part of the integrated assessment process and may determine tax payable, it must be read consistently with the assessment order. Where the order gives no reasons or discussion for rejecting the only Chapter VI-A deduction claimed, a contrary computation-sheet disallowance lacks a discernible basis. The disallowance and consequential demand are therefore unsustainable, and the order sustaining them is set aside.

A standard Deficiency Memo format prescribed in Annexure-I to CBIC Circular No. 31/2026-Customs must be used immediately for every drawback claim processed under Section 74 of the Customs Act, 1962. The requirement addresses the absence of a uniform format and is intended to ensure consistency, transparency and timely disposal of drawback claims. Additional/Joint Commissioners and Deputy/Assistant Commissioners must sensitise officers under their charge and ensure strict compliance with the prescribed format.

Brand Rate of Drawback applications must be received and processed by the Brand Rate Fixation Cell under the prescribed procedure. Original duty-paid documents are generally not required for post-facto endorsement or defacement; up to 5% of originals of self-attested copies may be selected for risk-based cross-verification, focusing on core, high-value, or higher-duty inputs. The Cell must scrutinise claims, obtain verification where required, apply the prescribed checklist, address deficiencies promptly, and prepare a clear recommendation through the designated approval channel. Proposals for fixation or determination must be submitted to the Commissioner within the stipulated time, whose approval constitutes final determination of the drawback amount or rate. The procedure takes immediate effect.

Section 49 storage facilitation for imported air cargo requires prompt written or email notice to importers when clearance is delayed by Customs or statutory processes, followed by custodial reminders where goods remain uncleared. Complete storage applications should ordinarily be decided within three working days; where another statutory authority is consulted, the request may be determined on merits after the prescribed response period, subject to revenue, security and regulatory considerations. Detention or demurrage waiver certificates may be issued only where legally admissible and after verification, specifying the attributable period, reasons, relevant status and reference number. These measures create no automatic right to storage permission or waiver, and procedures for disposal of uncleared goods remain unaffected.

Empty import containers manifested by shipping lines and international transshipment containers carrying cargo not intended for clearance in India are excluded from the container-scanning requirement. The exclusion applies as a trade-facilitation measure during phased enhancement of port container scanning. Containers within these categories may nevertheless undergo examination, including scanning, where specific intelligence is received from revenue intelligence or field formations. Containers in the excluded categories remain outside scanning even if selected through the National Committee for Targeting Cargo, and stakeholders must ensure compliance with these instructions.

Partial de-notification removes 11,525 square metres from the Customs-notified premises of a Container Freight Station, reducing the notified area from 94,325 square metres to 82,800 square metres. The revised layout plan identifies the retained Customs Area and excluded land. The operator's appointment as Customs Custodian and approval as a Customs Cargo Service Provider are confined to the retained area. The validity and other conditions of those existing approvals remain unchanged, and prior obligations continue unless expressly modified. The revised notified-area arrangement takes effect from issuance.

Seven obsolete FEMA circulars are withdrawn following a review of circulars issued since June 2000. The withdrawn directions concern external commercial borrowings, including overseas rupee-denominated bonds, infrastructure-sector liberalisation, service imports, technical know-how and licence fees, and ECBs by a development finance institution; rupee borrowing and lending through investments by non-residents in specified bonds; and the Money Transfer Service Scheme sub-agent list. Their withdrawal reflects subsequent regulatory amendments, redundancy, overlap or supersession by later directions. Authorised Persons must notify affected constituents, while any permissions or approvals required under other laws remain unaffected.

Suspension of 544 Standard Input Output Norms (SIONs) is proposed because they remained unutilised under the Advance Authorisation and Duty-Free Import Authorisation schemes during the preceding three financial years. DGFT invites exporters, importers, export promotion bodies, industry associations and other stakeholders to submit comments and supporting material within 15 days, particularly reasons for retaining any listed SION and details of actual or proposed scheme utilisation. Following the consultation period and consideration of submissions, the listed SIONs may be suspended; comments received after the deadline may not be considered.