Parts designed and manufactured solely or principally for a particular machine are classified with that machine under Note 2 to Section XVI, unless a specified exclusion applies. Pins, bolts, diaphragms, valves, gaskets, seals, bushes, liners and allied items made exclusively for GEHO slurry pumps, with no independent function or use in other machinery, qualify as pump parts rather than residual material-based goods. In the absence of evidence of dual use or classification as interchangeable parts of general use, the declared classification as relevant pump and valve parts prevails, rendering consequential differential duty, interest, confiscation, fine and penalties unsustainable.

Lending an Importer-Exporter Code for consideration breaches the Foreign Trade Policy requirement that imports and exports use the code allotted to the concerned person and may attract customs penalty under Section 112. Penal liability must nevertheless remain proportionate to the established contravention; use of a different code in the offending import establishes no nexus with earlier lending. Penalty under Section 114AA is inapplicable where the subsequent import was filed under the importing entity's own code and is unconnected with the lender's earlier transactions.

Customs undervaluation allegations require authenticated electronic records and verified supplier invoices; electronic data must meet statutory certification and procedural safeguards, while unsigned, unattested invoices require proof of origin and authenticity. Transaction value may be rejected only upon substantiated reasons to doubt it and compliance with prescribed valuation procedures; contemporaneous import values should be examined where relevant. Duty attaches to the importer filing the bill of entry, so liabilities of separate IEC-holding entities cannot be recovered from another proprietor merely alleged to be a proxy. Confiscation and redemption fine require goods to remain available for confiscation. Absent these conditions, valuation-based duty, interest and penalty consequences lack legal foundation.

Pre-import condition breaches attract IGST only for imports shown, through bill-of-entry-wise and raw-material-wise import-export correlation, to have preceded the corresponding exports. Subsequent discharge of export obligations or export-obligation-discharge certificates does not itself preserve unconditional IGST exemption where an actual breach is established; the liability must be regularised under the applicable procedure. Authorisation-wise quantification is insufficient, particularly where valid clubbing of advance authorisations must be given effect. Interest, confiscation, redemption fine and penalty require substantive statutory authority and are not sustainable for the described IGST regularisation during the relevant period, especially where authorisation particulars were disclosed.

Under the Customs Act, a legal ground based on test reports already included in the assessment record is not additional evidence. Prior acceptance of a proposed assessment or waiver of personal hearing does not preclude a statutory appeal where omission of the ground was neither wilful nor unreasonable. Iron ore Fe content for export-duty classification and assessment must be calculated on a Wet Metric Ton basis, reflecting total goods weight including moisture. Contractual pricing on a Dry Metric Ton basis does not govern tariff classification or export-duty rates. DMT-based assessment requires fresh determination of Fe percentage, classification, value and duty using test reports, moisture content and assessment records.

Written acceptance of enhanced customs valuation under Section 17(5) dispenses only with the requirement for a speaking reassessment order; it does not waive the importer's statutory right to appeal or challenge rejection of the declared transaction value. Rejection requires compliance with Section 14 and Rule 12(2), including written grounds for doubting the declared value. General consent letters referring to contemporaneous imports, without comparable data on quantity, quality and timing, do not prove voluntary abandonment of valuation rights. Statutory appeal rights cannot be defeated by acquiescence, making reassessment and appellate rejection founded solely on written acceptance unsustainable.

Breach of import conditions for gold jewellery, including passenger ineligibility, inadequate foreign stay, non-declaration, non-payment of duty in convertible foreign currency and excess quantity, renders restricted gold prohibited goods for confiscation purposes. Redemption in lieu of confiscation under Section 125 of the Customs Act is discretionary for prohibited goods, not a right. Refusal may rest on non-declaration, concealment, the nature and quantity of gold, and failure to establish lawful import. Judicial review under Article 226 is limited and does not extend to substituting that discretion unless its exercise is arbitrary or perverse.

Statutory appellate remedy against customs confiscation and penalty orders remains effective despite a mandatory pre-deposit of 7.5% of the penalty. The pre-deposit requirement alone does not justify writ intervention where adjudication has addressed the factual claim that the seized item was personal jewellery and found it to be a gold strip fashioned as a kada. Fact-specific precedent does not require writ jurisdiction whenever an appeal is available. Time spent pursuing writ proceedings may be claimed for exclusion under Section 14 of the Limitation Act before the appellate authority; the petitioner must pursue the statutory appeal.

Section 110(5) of the Customs Act limits freezing of a bank account to an initial six months, extendable by a further six months only on recorded reasons. Once the maximum twelve-month period expires, continued freezing is impermissible. Issuance of a show-cause notice under Section 124 does not independently authorise continuation of the freezing beyond that statutory period. The bank account must therefore be de-frozen after expiry of the maximum permissible period.

Customs duty exemption disputes fall outside High Court appellate jurisdiction under Sections 130 and 130E where they intrinsically concern the rate of duty or valuation for assessment. The jurisdictional exclusion has broad scope and covers entitlement to exemption for stores imported for salvage operations, because such questions are connected with duty assessment and may have wider fiscal ramifications. Challenges to Tribunal orders on those issues lie exclusively before the Supreme Court under Section 130E, rather than the High Court.

Statutory appellate remedy for a customs provisional-release order may displace writ intervention, even where the petitioner alleges that relied-upon reports were not supplied. The customs authority must supply those reports, while any request for testing by an independent agency may be considered by the appropriate authority. The resulting test report should be circulated before a final decision. The appellate process is to be considered expeditiously, rather than remanding the provisional-release matter in writ jurisdiction.

Section 28(9A)(b) treats a pending proceeding and operative interim protection that prevent customs determination as an enumerated circumstance, causing the Section 28(9) period to run from cessation of that circumstance. A Call Book transfer is consequential only, and an administrative circular cannot override this statutory timing rule. Where noticees request deferment pending related proceedings, know why determination is postponed, and fail to report cessation, communication requirements may be substantially fulfilled. Availability of an effective statutory appeal and the bar on approbation and reprobation weigh against discretionary writ relief; substantive duty-demand issues remain available in the appellate process.

Appellate Authority must decide the customs dispute independently on its own merits and without being influenced by prior judicial observations. The impugned order remained undisturbed, while the special leave petition was disposed of subject to that clarification. Pending interlocutory applications were also disposed of. This preserves an uninfluenced merits determination at the appellate stage despite non-interference with the impugned order.

Internal TNMM for IT services requires separate benchmarking of AE and non-AE segments where their functions and risks differ. Certified segmental results included in transfer-pricing records can support the analysis; audited segmental accounts are not required. An AE captive-service margin within the arm's-length range supports acceptance of the AE segment. Ind AS 32 presentation of CCDs as equity does not change their underlying debt character. Interest remains deductible while CCDs are outstanding, subject to confirmation that no actual conversion or redemption occurred during the relevant year.

Penalty for under-reporting of income was not leviable where the income returned in response to a reassessment notice was accepted without any addition. The penalty order failed to identify how the accepted returned income constituted under-reporting. Consistent treatment was required because penalty had been dropped on identical facts for an earlier assessment year. The circumstances also fell within the exclusion for a bona fide explanation accompanied by full disclosure of material facts. The penalty was therefore directed to be deleted.

Capital gains from independently registered sale deeds accrue in the respective assessment years of transfer, rather than collectively in one year. Reassessment may be sustained where returns were only processed under section 143(1) and subsequent scrutiny information indicates transfers in other years. Stamp-duty valuation, indexed cost and proportionate capital-gains computation require fresh factual examination. Deduction claims for eligible reinvestment may be considered in appellate proceedings despite no revised return. Tax relief is required to prevent the same capital gains being taxed twice across assessment years. Concealment penalties do not apply where transactions were disclosed, the year of taxability was debatable, and additions partly arose from deeming valuation.

Reassessment jurisdiction under Section 147 requires a correct factual foundation and genuine application of mind to material available to the Assessing Officer. Treating an assessee as a non-filer despite a return having been filed under Section 139(1) makes the satisfaction underlying the notice under Section 148A(b), the order under Section 148A(d), and the reassessment factually erroneous. Reliance solely on portal information without verifying the return record renders the assumption of jurisdiction unsustainable. The reassessment proceedings and consequential reassessment order were therefore invalid and set aside.

Capital-asset classification of the land and the alternative reinvestment-exemption claim require complete supporting material, including the sale agreement, diversion orders, sale documents and reinvestment evidence. Where that material was absent before the Assessing Officer and appellate forums, income cannot be properly computed or the claims determined on merits. Assessment under Sections 144 read with 147 therefore requires fresh adjudication by the original authority through a speaking order after examination of complete evidence.

Partial income-tax refunds comprising refundable tax and accrued interest under Section 244A must be appropriated first towards the interest component and then towards principal tax. Section 244A treats the refund due as including both tax and interest and aims to compensate the assessee for the Revenue's retention of refundable money. Adjusting a partial payment first against tax would stop further interest accruing on the unpaid interest balance, giving the Revenue an unjust advantage. Interest-first appropriation preserves full compensation for the time value of money and promotes equitable tax administration.

Interest paid or credited to bodies constituted under Central, State or Provincial legislation qualifies for the notified tax-deduction exemption because statutory creation, rather than mere incorporation or regulation under general law, is decisive. The exemption also applies independently to companies whose entire share capital is Government-held. Interest earned on Government scheme funds held by companies solely as nodal or implementing agencies is not their income where beneficial ownership remains with Government; no tax-deduction obligation arises. Payments to temples require recipient-wise verification of declarations, tax returns, condonation materials and other evidence before relief from default can be determined under the first proviso to section 201(1).