Bulk drugs and active pharmaceutical ingredients imported under Chapters 28 or 29 may fall within the 5% IGST entry for all drugs and medicines where they qualify as drugs under the Drugs and Cosmetics Act, including substances intended as drug components. Their use in formulation manufacture, testing, clinical research, or bioavailability and bioequivalence studies does not change that character. The phrase covering goods under any Chapter extends the entry beyond finished formulations, and the specific drugs-and-medicines description prevails over general chemical classifications. Eligibility remains subject to the relevant nil-rate exclusion for particular goods.

Woven man-made fibre textile rolls designed exclusively for garment labels, supplied in strips and suitable for durable printing, fall under CTI 5807 10 20 as woven labels or similar articles of man-made fibre. Their unprinted condition and cutting after import do not alter their character as labels; the specific man-made fibre entry prevails over the residual entry, subject to verification of the declared description, construction and composition at import. As articles under Heading 5807, the rolls fall within Entry 370 of Schedule I to Notification No. 09/2025-Integrated Tax (Rate) and attract IGST at 5 per cent.

End-use concessional duty for imported lithium-ion cells under the IGCR Rules requires their use in manufacturing the specified battery or battery pack. Manufacture requires emergence of a new product with a distinct nature, character, use or name; cells damaged or rejected and sold as scrap do not meet that condition. Where no prescribed process-loss or wastage tolerance applies, scrapped cells are treated as unutilised or defective goods. Differential duty, being the difference between normal import duty and concessional duty, is recoverable on the imported goods' assessed quantity and value with applicable interest, rather than proportionately to scrap sale proceeds.

Customs tariff classification of the Excalibur Hybrid X archery crossbow turns on the General Rules for Interpretation, Chapter Notes and HSN Explanatory Notes. Chapter 93 excludes bows and arrows, while Heading 9506 expressly covers archery equipment, including bows, arrows and targets. Because the crossbow propels bolts or arrows through stored mechanical energy in its limbs and string, rather than explosive charge, compressed air, gas or a firearm mechanism, it falls within the residual sub-heading for other sports or outdoor-game equipment. Classification therefore lies under Customs Tariff Item 9506 99 90, not Item 9304 00 00.

Imported automotive components must be classified under the specific tariff entry determined by their material composition and sole or principal vehicular use. A protector tube made entirely of PVC falls under the PVC heading and cannot receive a preference claimed under a rubber heading. A brake-hose bracket and a brake-fluid-flow connector designed specifically for automobile brake systems fall within vehicle-parts classification rather than general metal articles or Chapter 39 plastic fittings. Incorrect self-assessment causing duty short payment, supported by changed declarations, discrepancies and voluntary differential-duty payments, permits extended limitation and penalties for intentional misdeclaration.

Section 123 of the Customs Act shifts the burden of proving that notified goods are not smuggled only where seizure rests on reasonable belief supported by tangible material and cumulative circumstances. Inland seizure or absence of foreign markings is not independently decisive; carriage, concealment, admissions, markings, provenance, accounting records and other incriminating material require collective assessment. Domestic acquisition may be established on a preponderance of probabilities through reliable documentary and circumstantial evidence, without invariably proving uninterrupted physical identity of fungible gold. Tax invoices for domestic purchases could not be rejected without findings that they were false or unrelated to business stock, rendering confiscation and penalty unsustainable.

Goods sold through duty-free shops beyond the customs barrier, including warehoused or re-exported goods, remain imported goods from their entry into Indian territorial waters. Fiscal principles limiting customs duty and sales tax do not create immunity from domestic non-fiscal regulation. Restrictions or prohibitions under other domestic laws render such goods prohibited goods for customs purposes. Import licensing and other regulatory requirements therefore continue to apply despite warehousing, non-clearance for home consumption, or an intended re-export.

Estimated disallowances of alleged inflated purchases, where the extent of inflation is unproved, do not by themselves establish concealment for penalty under section 271(1)(c); penalty deletions were sustained. Documentary support for purchase claims, including invoices, vehicle details and ledgers, prevents their characterisation as wholly unsubstantiated expenditure for misreporting under section 270A(9)(c), although the taxpayer's explanation did not qualify for the section 270A(6) exception; penalty deletions were sustained. A separate section 271AAC penalty on cash received back from suppliers does not preclude a section 270A penalty absent a one-to-one correlation with the estimated purchase-inflation addition.

Assessment validity under Sections 143(3) and 153A depends on verifying whether it was founded on the original notice or a later notice issued after the initial proceedings were dropped. Where the search authorisation did not cover the assessee, the effect of the fresh Section 153A notice, subsequent Section 142(1) notices, and any return filed in response requires factual examination. The appellate authority may exercise powers under Section 250(4) to conduct or direct further inquiry, including obtaining a remand report, before deciding jurisdictional objections and remaining grounds.

Closing stock damaged while factory premises were under bank possession may be valued at cost or net realisable value, whichever is lower, where that accords with the consistently disclosed accounting method. Internet-price revaluation does not justify an addition unless it disproves the reduced recoverable value; the closing-stock addition was deleted. Cash deposits during demonetisation recorded as cash sales in audited books, supported by sale bills, delivery challans, sales registers and stock registers, were not unexplained money absent contrary material. The deposits were explained by the non-performing bank account and takeover of the business and residential premises, so the addition under Section 69A was deleted.

Substantiation of tax claims is required for deductions, exemptions, and explanations of entries in seized records. A section 80C deduction is available only to the extent qualifying payments are evidenced; unsupported amounts are disallowed. HRA exemption requires documentary proof of rent payment and entitlement, with the taxpayer bearing the onus. Entries in seized Excel sheets recording loans advanced may be treated as unexplained investment where no material establishes a different classification or underlying business nature. Unsupported claims and explanations therefore fail.

Long-term capital gains from listed-share sales supported by contract notes, demat statements and bank records cannot be characterised as non-genuine accommodation entries solely because of general investigation material or abnormal price appreciation. Purchases through a recognised broker, banking-channel payments, demat credits, exchange sales and banking-channel sale proceeds constitute direct documentary evidence unless disproved as false or fabricated. Such treatment requires evidence linking the taxpayer to operators or price-rigging, such as a cash trail, commission payment, pre-arranged transactions, or participation in manipulation. Suspicion and the human-probabilities test cannot replace proof.

Unexplained cash-credit treatment of share-sale proceeds and consequential share investment requires evidence directly connecting the taxpayer with accommodation-entry transactions. Third-party statements and general investigation material may trigger enquiry but, without corroboration, cannot displace unrebutted purchase bills, contract notes, bank records, and banking-channel fund movements; suspicion cannot substitute proof. Finality of appellate deletion concerning the original share purchase removes the factual basis for treating subsequent sale proceeds and related investment as unexplained, requiring deletion of the additions.

Section 69A places the burden on a person found in possession of cash to provide a credible, corroborated explanation of its source and ownership. A claim that cash belonged to third parties is insufficient where their particulars are incomplete, they cannot be verified, and no evidence establishes the source or ownership of the money. Mere denial of ownership, particularly when no claimant emerges over time, does not rebut the presumption arising from possession. Cash lacking a satisfactorily supported explanation may therefore be assessed as unexplained money.

Undisclosed real-estate sale receipts constitute gross collections, so where no evidence shows that corresponding costs or investments were also undisclosed, taxability is confined to the embedded profit; the prior profit estimate was accepted as adequate. Likewise, non-genuine purchase invoices do not justify disallowing the full purchase value when material consumption, construction activity, sales and book results remain accepted; only the grey-market saving or embedded profit may be estimated. Seized electronic data certified under the Evidence Act and corroborated by unretracted search statements remain admissible and reliable. A delayed, unsupported retraction does not displace their evidentiary value.

Amended tax-inclusive income computation requires taxes, duties, cess and fees incurred in relation to goods or services to be included when calculating business income. Consequently, GST and service-tax liabilities collected from customers and paid after the return-filing date remain subject to disallowance under section 43B even if not routed through the profit and loss account. Interest on delayed remittance of TDS is treated as penal and not deductible as business expenditure. Commission-expense discrepancies require reconciliation, cash visa-fee payments require verification of each individual payment for cash-payment restrictions, and differences between declared receipts and Form 26AS receipts require reconciliation with books and supporting evidence.

Reassessment jurisdiction requires a reason to believe founded on correct facts and independent verification. Recorded reasons based on the incorrect premise that only summary processing occurred, despite a completed scrutiny assessment, cannot be cured as a clerical defect. Similarly, unverified Investigation Wing information unsupported by corresponding bank credits does not establish a valid basis for reopening. Sale proceeds of investments previously recorded in the books and balance sheet, received through banking channels, are not loans, deposits, share application money, or unexplained cash credits. Such disclosed investment realisations cannot be added as unexplained credits.

Section 80G may allow a deduction for qualifying donations even when they form part of corporate social responsibility expenditure. Explanation 2 to section 37(1) disallows CSR expenditure in computing business income but does not impose a general bar on a specific donation deduction, except for donations expressly excluded under section 80G. Where statutory conditions are otherwise satisfied, CSR character alone does not defeat the claim. Given divergent judicial views, allowing the deduction constitutes a plausible and legally sustainable view. Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests and cannot replace one permissible view with another; revision was therefore invalid.

Section 12AB registration requires a prima facie enquiry into charitable objects, the genuineness of actual or proposed activities, and material legal compliance; it is not a full assessment of every receipt or expenditure. Verified charitable medical activities, including eye camps, patient treatment, medical equipment and hospital facilities, support genuineness where explanations remain undisplaced by contrary evidence. Related-party rent or incomplete supporting records do not alone prove a sham arrangement, private benefit, or diversion of funds. Section 80G(5) approval cannot be refused solely because section 12AB registration was denied where no independent breach of section 80G(5) conditions or rule 11AA is identified.

Partners' admitted capital contributions, where the contributors are identified, explain the nature and source of credits in a partnership firm's books for Section 68 purposes. Questions concerning a partner's creditworthiness or the source of contributed funds must be examined in that partner's individual assessment, rather than through an unexplained-cash-credit addition to the firm. Accordingly, an addition based solely on doubts about partners' sources is not sustainable against the firm, while assessment of those sources remains open in the partners' individual cases. A short delay attributable to serious illness may be condoned where sufficient cause exists and substantial justice favours merits adjudication.