Reassessment notices must be initiated through the faceless assessment framework rather than by the Jurisdictional Assessing Officer where algorithm-based random allocation governs reassessment proceedings. A final assessment order issued under the faceless regime does not cure the initial jurisdictional defect. Where the final order is already challenged before the Commissioner of Income Tax (Appeals), the jurisdictional objection should be raised and considered in that statutory appeal, applying the relevant High Court precedents. The assessment order need not be independently quashed in writ proceedings when the pending appeal can address the objection.

Penalty proceedings for underreporting are independent of assessment proceedings. Failure to initiate penalty proceedings under section 270A while completing a reassessment does not, by itself, make the assessment order erroneous or prejudicial to the interests of the Revenue for revisional purposes. Revisional jurisdiction was therefore held unjustified where it rested solely on that omission, and the revisional order was quashed. A contrary Tribunal decision relied upon by the Revenue was distinguished. The assessee's appeal succeeded.

Material seized from a company director who managed its day-to-day affairs and was searched simultaneously could be used for the company's assessment under section 153A; separate proceedings under section 153C were unnecessary. The Tribunal found the consolidated section 153D approval for four assessment years mechanical because it showed no year-wise application of mind, quashing the assessments. For unabated years, the consistently accepted Project Completion Method could not be replaced by the Percentage Completion Method without relevant seized material, rejection of accounts under section 145(3), or a cogent factual basis; the resulting additions were deleted. Additions for both receipts and payments reflected in the same seized papers were also deleted as double taxation of income already offered and accepted.

TNMM comparability for marketing-support commission should primarily rest on functional, asset and risk analysis where reliable segmental data exists. A low-risk indenting-services segment without inventory or credit risk may be comparable despite the entity's wider trading activity or different products. LIBOR is the appropriate benchmark for foreign-currency loans to wholly owned subsidiaries; additional risk mark-up requires demonstrated differential risk, and contractual LIBOR-plus rates may be arm's length. Delayed associated-enterprise receivables remain separately examinable international transactions, but notional interest should not be charged where working-capital adjustment already captures the receivables effect and the tested party's adjusted margin exceeds comparable margins, subject to verification.

Biometric-based Aadhaar authentication for Gujarat GST registration applicants is conducted through Facilitation Centres designated for specified jurisdictional offices. Applicants must attend the centre mapped to their relevant State Tax unit for biometric authentication, photograph capture and verification of original documents corresponding to documents uploaded with the registration application. Centres are allocated across Ahmedabad, Gandhinagar, Mehsana, Vadodara, Surat, Bhavnagar, Rajkot, Junagadh and Gandhidham. The location-specific verification framework takes effect from 7 November 2023.

Section 2(9)(D) treats a transaction as benami where the person providing consideration is untraceable or fictitious. For immovable property, claimed loans may fail to establish the source of consideration where alleged lenders' financial capacity and fund sources are unproved, supporting loan documentation is absent, and no repayment or interest payment is evidenced. Failure to explain the balance consideration and validation fee can further support the conclusion that the consideration provider was untraceable or fictitious. On these stated grounds, provisional attachment of the land as benami property was confirmed and the appeal was dismissed.

The third limb of a benami transaction, requiring property to be held for the beneficial owner's future benefit, carries no fixed time limit and need not be established when provisional attachment is made. Provisional attachment may occur immediately to prevent alienation or transfer. Funds supplied by the beneficial owner for relatives' property purchases, coupled with their failure to substantiate independent income or a documented loan arrangement, supported treatment of the transactions as benami. Love and affection did not establish a genuine loan explanation where no supporting evidence existed. The transactions were treated as benami, and the confirmation of provisional attachment was sustained.

Customs clearance facilitation restores acceptance of an undertaking in lieu of the bond otherwise required in specified clearance cases during lockdown-related constraints. The facility applies from 8 May 2021 until 30 June 2021. Importers or exporters availing it must replace the undertaking with a proper bond by 15 July 2021. Existing terms and conditions governing the undertaking-for-bond mechanism, including their amendment, remain unchanged.

Laser imagers that merely print diagnostic data received from other equipment lack independent diagnostic capability and are accessories rather than diagnostic instruments or apparatus. Chapter 90 Note 2(b) permits classification of an accessory with a machine only where it is solely or principally suitable for use with a particular kind of machine or machines under the same tariff heading. Because the imported laser imagers were compatible with equipment classifiable under both CTH 9018 and CTH 9022, they could not be classified with either group and fell under the residuary rule in Note 2(c). They were consequently classifiable under CTH 9033 00 00, not CTH 9018 90 19.

Provisional clearance of ongoing and future imports claiming specified customs exemption benefits was made conditional during the pendency of an appeal. Arguable issues were identified for final hearing, while Revenue's interest in securing potential duty liabilities required protection. High Court therefore adopted an equitable interim arrangement rather than granting an unconditional stay of the customs appellate order. Importers may clear consignments provisionally by furnishing a bond covering the full differential duty, including applicable duties, cess and surcharges, and a bank guarantee for half of that differential duty. The arrangement is without prejudice to the final appeal, and all rights and contentions remain open.

A Customs Broker's acceptance of classification and valuation cannot bind an importer without proven authority to do so. Examination conducted in the Broker's presence therefore did not amount to examination in the importer's presence, and the assessment was vitiated by breach of natural justice. Visual examination alone did not establish that imported heavy melting scrap was misdeclared as to classification or value, particularly where the Department lacked specialist opinion, market enquiry or testing to support its assessment of secondary and defective coils. Confiscation, redemption fine and penalty were consequently unsustainable.

GST composition dealers cannot directly make inter-State outward sales of goods while remaining under the composition scheme. Movement of goods from one State to another pursuant to sale attracts the restriction, and payment or invoicing arrangements cannot cure it. A customer or payment originating in another State does not itself make a supply inter-State; actual delivery, movement and place-of-supply facts govern. A genuine independent reseller may separately make an inter-State sale, while businesses undertaking direct inter-State sales should operate under the regular GST scheme.

SEBI's Accredited Investor framework enables eligible investors and entities to obtain certification that may allow lower minimum investment thresholds for Portfolio Management Services, Alternative Investment Funds and other alternative investment products, along with applicable regulatory flexibilities. PMS Bazaar and NSDL Database Management Limited's Accreditation Agency facilitate end-to-end applications, subject to required documentation and prescribed payment. Assistance is available to individual investors and eligible clients of investment providers without additional platform, service or processing charges, while prescribed certification fees remain payable.

The amendments expand Ind AS 107 disclosures for investments, contingent cash-flow features and contracts referencing nature-dependent electricity. Entities must provide a single note on qualifying electricity contracts, covering cash-flow uncertainty, commitments, onerous-contract assessments, electricity purchases, unused electricity and related sales. Ind AS 109 defines these contracts, permits specified hedge-accounting designations, and sets expected-usage and transition requirements. Classification and measurement changes refine derecognition through electronic payment systems and the assessment of contractual cash flows as solely payments of principal and interest.

GST Facilitation Centres are designated for purposes under the Gujarat Goods and Services Tax Rules, 2017, replacing the earlier designation of Facilitation Centres. Twelve GST Seva Kendras are specified across Gujarat. Each centre is assigned a Head of the Biometric Aadhaar Authentication Officer, designated as a State Tax Officer, as its contact person. Respective Joint Commissioners of State Tax are assigned as division-level contacts, creating an organised framework for biometric Aadhaar authentication and related functions under the Rules.

Importers claiming concessional-duty treatment must give one-time prior information, execute a continuity bond, provide pre-import consignment details, and upload the intimation with the bill of entry. Job work is permitted subject to prescribed intimations, challans, accounts, and a six-month retention limit at job-worker premises. Imported goods must be used for the intended purpose or re-exported within six months; clearance of unutilised or defective goods requires payment of differential duty and interest. Quarterly returns and detailed importer and job-worker accounts are mandatory, and contraventions attract penalties and duty-recovery action.

Penalties for shortages of duty-free gold and silver jewellery require evidence of intentional diversion to evade customs duty. Where the proprietorship concern itself reported the shortage, theft was indicated, and differential duty with interest was paid, penalties on the concern and the person supervising manufacturing operations do not sustain. Statements from persons unavailable for permitted cross-examination cannot be relied on without compliance with statutory conditions and corroboration; an unmatched police recovery does not conclusively establish involvement in removal of the goods. A proprietorship concern and its proprietor are legally the same entity, preventing separate penalties on both. Differential customs duty and interest remain payable, while all penalties are set aside.

Limitation for customs appeals permits exclusion of time during which appeal papers, filed within the prescribed period, remained before an incorrect forum; the first appeal was treated as timely and remanded for merits determination. An appeal emailed and dispatched within the statutory period could not be rejected as time-barred; alternatively, any marginal delay in physical receipt fell within the condonable period. Refund of customs duty paid under protest was available for finally assessed bills of entry where assessment accepted the importer's declared classification and no reclassification proceedings displaced the protest. Each bill of entry constituted a separate assessment, so proceedings concerning other bills could not defer refund. Refund was confined to finally assessed bills, excluding provisionally assessed bills.

Rejection of the declared transaction value for imported brass scrap required specific evidence of contemporaneous imports of identical goods under Rule 5. The Tribunal found that the authorities had not explained the revised classification of secondary defective brass pipes or supplied the requisite valuation particulars; visual examination alone could not displace the declared description, particularly where no tariff size restriction applied to brass scrap. The enhanced value and differential duty demand were therefore unsustainable. Misdeclaration was also not established because the contractual specification, broad tariff coverage, and chartered engineer's report conflicted with the departmental visual assessment, while no documentary evidence proved serviceability or misdeclaration. Confiscation, redemption fine and penalty were consequently set aside.

Registered persons with aggregate annual turnover not exceeding two crore rupees in financial year 2023-24 are exempt from furnishing the annual return for that financial year. The exemption operates under the first proviso to section 44 of the Gujarat Goods and Services Tax Act, 2017.