PAN-linked bank accounts can support initiation of assessment proceedings where cash deposits were made in an account whose PAN and partnership details were not updated, despite a claim that the original partnership firm no longer existed. Continued use of the account meant that proceedings initiated against the entity identified through its linked PAN were not invalid on that ground. However, the assertion that the deposits belonged to a newly constituted firm required examination. Fresh assessment following verification of deposit ownership was therefore justified.

Assessment-year alignment governs taxation of alleged on-money payments as unexplained investment. Information obtained during a builder survey must identify the statement or material substantiating the quantified payment. Where bearer cheques evidencing the alleged payment were issued from September 2012 onward, they fell in financial year 2012-13, relevant to assessment year 2013-14. The transaction could therefore not be brought to tax as unexplained investment in assessment year 2012-13, and the addition for that year was deleted.

Article 12(4) of the India-Netherlands tax treaty treats consideration for industrial, commercial or scientific experience as royalty only where know-how is transferred so that the recipient can independently use the knowledge, skill or experience. Information technology, operational, marketing, safety, engineering, administrative and legal support involved service performance and did not make available know-how to the Indian entity. Cost allocations without markup represented reimbursement of expenditure rather than royalty consideration. Management and business support service fees therefore fell outside the treaty definition of royalty, and the related addition was deleted.

Receipts reflected under an earlier PAN cannot support an estimated-profit addition where Form 26AS corrections, ledgers and audited accounts establish that the same receipts were recorded and offered to tax under the correct PAN. This prevents duplicate taxation of already disclosed contract receipts and service charges. Credit-card payments cannot be treated as unexplained expenditure under Section 69C where they were paid through the regular bank account, recorded as business expenditure, and no material shows an unexplained source. Reliable accounting records therefore preclude separate additions for previously accounted income or expenditure.

Section 153C treats, for a person other than the searched person, the Assessing Officer's receipt or handover of seized material as the initiation date under its first proviso. Section 153C(3) excludes its application to searches initiated on or after 1 April 2021. Where satisfaction was recorded and seized material was taken up for proceedings on 14 November 2022, jurisdiction under Section 153C was unavailable. The original search date relating to the searched persons could not govern proceedings against the other assessee. The notice and consequential assessment therefore lacked jurisdiction and were quashed.

Notional annual letting value of completed but unsold flats held by a builder as stock-in-trade was not taxable as income from house property for Assessment Year 2017-18. Section 23(5), effective from 1 April 2018, subsequently created a specific framework for determining annual value of stock-in-trade and allowed a temporary nil valuation period. Before that effective date, no specific charging provision authorised taxation of notional annual letting value for such unsold inventory. Charging provisions require strict construction and cannot be extended without clear statutory authority.

Penalty for misreporting income cannot rest solely on disallowance of a disclosed deduction claim for lack of satisfaction about a donation's genuineness. Misreporting requires material showing false evidence, suppression, deliberate misrepresentation, or knowingly fabricated particulars. Penalty proceedings remain independent of assessment proceedings, and failure to challenge the quantum addition does not amount to an admission of misreporting. A penalty for misreporting is also unsustainable where the applicable statutory limb is not specified. On these grounds, the penalty relating to the deduction claim was deleted.

Reassessment notices must be issued and dispatched within the prescribed limitation period; signing the notice before the deadline is insufficient where issuance and dispatch occur after it. A notice signed on 31 March 2021 but issued and dispatched on 1 April 2021 was therefore time-barred and invalid. Because the consequential reassessment order rested entirely on the invalid notice, it could not survive and was likewise invalid.

Penalty for misreporting under section 270A is addressed in relation to a disallowed deduction for political contributions under section 80GGC. Disallowance of a transparently disclosed claim, without material showing false evidence, suppression of facts or deliberate misrepresentation, does not by itself establish misreporting. Penalty proceedings must also identify the applicable limb of section 270A(9); failure to specify that statutory basis makes a penalty for under-reporting arising from misreporting unsustainable. On these grounds, the section 270A penalty was deleted, although other objections to the penalty proceedings failed.

India and Thailand discussed expansion of bilateral trade and investment, stronger business-to-business linkages, trade-promotion activities, and wider market opportunities for enterprises. Progress in reviewing the ASEAN-India Trade in Goods Agreement was considered, with emphasis on time-bound engagement through the India-Thailand Joint Trade Committee. The discussions supported a balanced and mutually beneficial framework for greater market access, resolution of market-access issues, and stronger regional and global supply-chain linkages.

Turant Suvidha Kendra (TSK) is to operate as a single-point interface for trade facilitation within the Trade Facilitation Cell under centralized customs functions. Procedures must address location, document handling and safe custody, electronic record maintenance, staffing, training and legal compliance. TSK establishment must specify its functions, timings, contact details and staffing, with guidance issued for importers, Customs Brokers, officers and staff. Its operational efficiency must be monitored, and the prescribed actions operate as standing orders.

Registration on the Centralized EPR Portal is mandatory for importers of plastic packaging, packaged commodities, plastic raw materials, and intermediate materials used for plastic packaging. Customs officers are to verify EPR registration certificates and facilitate clearance of covered import consignments. Certificates stating one-year validity are to be treated as one-time Registration Certificates not requiring renewal under the amended Plastic Waste Management Rules, and are valid proof of EPR registration for import clearance.

Commencement of the corporate insolvency resolution process on an operational creditor's application requires proof of operational debt and default, compliance with demand-notice requirements, an affidavit confirming no dispute, and supporting records. Invoices, purchase orders and ledger accounts may establish unpaid liability where it exceeds the statutory threshold. Dealings involving a corporate debtor's parent company and the creditor's sister concern do not negate the debtor's liability for its own transactions. Failure to reply to the demand notice supports the absence of a dispute and establishment of default.

The Enforcement Directorate sought an anti-corruption FIR against Pinarayi Vijayan, Veena T, P. A. Mohamed Riyas and others on material gathered during a money-laundering investigation. It alleged that Cochin Minerals and Rutile Ltd made fraudulent payments to Exalogic Solutions, Veena's now-defunct company, under the guise of IT consultancy services. Vijayan criticised the investigation as politically motivated and as an attempt to target the cooperative sector.

Central Government de-notifies 1.4310 hectares from the Information Technology and Information Technology Enabled Services Special Economic Zone at Rachenahalli, Nagavara and Tanisandra villages in Bangalore district, Karnataka. Exercising powers under the Special Economic Zones Act, 2005 and rule 8 of the Special Economic Zones Rules, 2006, the total designated area stands at 17.7681 hectares.

Evidentiary scrutiny of conflicting historical trading data is required in the challenge to regulatory penalties arising from an alleged misleading open-market share buyback announcement. The Securities Appellate Tribunal must examine the discrepancy between the investigation report and exchange-furnished trading data, determine which data accurately reflects the trading position, and record specific findings on identified discrepancies. The allegations concern inadequate buy orders despite available sell orders, failure to utilise the prescribed minimum buyback size, and fraudulent conduct under unfair trade practices and buyback requirements.

Interest incurred by a real-estate developer is deductible as revenue expenditure rather than capitalised to work-in-progress where consistent treatment under Section 36(1)(iii) continues and facts remain unchanged. No Section 14A disallowance, or related book-profit adjustment, arises where no exempt income is earned; the explanation effective from 1 April 2022 does not apply to the relevant assessment year. Foreign-exchange loss on monetary items is recognised in profit and loss and cannot be included in inventory or project cost. Corporate-guarantee commission is benchmarked at arm's length under an interest-saving approach considering creditworthiness, tenure, currency, lending comparables and shared interest benefit.

Central Government has expanded the sector-specific Special Economic Zone for Information Technology and Information Technology Enabled Services by including an additional area of 2.708437 hectares. The inclusion is made under the Special Economic Zones Act, 2005 and the Special Economic Zones Rules, 2006, following the developer's proposal and the Board of Approval's recommendation. The aggregate notified area becomes 5.412488 hectares. Specified parcels identified by Khasra Nos. 55, 57, 227/1, 227/2, 247/2, 247/3, 248 and 249/1 are incorporated into the Special Economic Zone.

Rescission of the earlier Special Economic Zone notification de-notifies the entire 60.70-hectare area established for Information Technology and Information Technology Enabled Services at Mamidipalli Village, Saroornagar Mandal, Ranga Reddy District, Telangana, on the proposal of M/s. Brahmani Infratech Limited. The Central Government exercises its power under the first proviso to rule 8 of the Special Economic Zones Rules, 2006 to rescind the prior notification, while preserving acts done and omissions occurring before the rescission took effect.

Passing off involving wholly dissimilar goods requires stronger proof of misrepresentation and a real likelihood of damage. Where protection is claimed for a business rather than particular goods, the claimant must show a sufficiently extensive reputation for the public to associate the other business with it. A reputation confined to telecommunications did not establish that liquor purchasers would associate the liquor business with the claimant. Independently, a prior artistic label comprising the word mark, font, design and colour scheme received copyright protection where identical reproduction constituted dishonest copying. Copyright in the artistic work supported injunctive protection despite the absence of an independently established passing-off claim.