Documented gift funding and traceable bank transfers can explain a spouse's contribution to an immovable-property purchase. Donor confirmation identifying fixed-deposit liquidation, together with matching same-date debit and credit entries, supported acceptance of the stated source. Regular mutual-fund SIPs for a minor child were likewise treated as explained where bank debits, modest periodic investments, and clearing credits supported the claim of salary savings. Consequently, the additions for unexplained property and mutual-fund investments were deleted; the reopening issue remained academic and computation required verification under law.

Natural justice is not breached where the taxpayer receives repeated opportunities, issue-specific show-cause notices, and consideration of replies and evidence; the challenge to assessment validity therefore failed. Cash deposits require credible proof of source and a transaction-specific cash trail; unsupported deposits were treated as unexplained money. Consideration for land-facilitation work was characterised as business income because the land was not established as a capital asset and no refundable obligation was proved. GST-reported sales omitted from the revised income-tax return were treated as undisclosed business receipts absent cogent rebuttal. The contested additions and assessment were sustained.

Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature.

Redevelopment hardship and displacement compensation received for vacating residential premises under a redevelopment agreement is treated as a capital receipt where it is not consideration for independent services or otherwise revenue in nature. Its taxability does not depend on alternative-accommodation rent or an erroneous offer to tax. Gross salary reported in Form 26AS does not by itself determine taxable salary; exempt components, including eligible gratuity, require component-wise examination against Form 16 and settlement records. Documentary proof of a qualifying donation and bank payment supports the deduction. Savings-bank interest included in gross total income qualifies for the corresponding deduction within the prescribed limit.

Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.

Skill-based online-game prizes fall within taxable income; the term "winnings" is not limited to chance-based games. However, online-gaming taxability applies only to real net winnings, not gross wallet credits. Repeated circulation of funds, player buy-ins and recycled gaming amounts cannot independently constitute taxable winnings, notwithstanding the bar on deducting expenditure. Where gaming activity results in a net loss and no real net winnings arise, an addition computed on gross online-gaming credits is unsustainable and must be deleted.

Customs-duty liability arising from confiscation and redemption is distinct from the original Bill of Entry assessment. Statutory interest, where payable, cannot accrue before that consequential liability is determined in confiscation proceedings, although departmental delay does not by itself eliminate interest. Interest charged from the original assessment until adjudication was therefore unsustainable and requires recomputation from determination of liability, subject to reassessment and payments or appropriations. Limited writ review may remain available despite an appellate remedy where undisputed facts raise only the legal question of the period for consequential-interest computation and do not challenge classification, confiscation, redemption fine, or penalties.

MEIS benefits under a beneficial export-incentive scheme cannot be refused solely because 'Y' was selected only for the first item in each electronic shipping bill, where genuine notified exports were made and the exporter otherwise declared an intention to claim rewards. The omission was treated as an inadvertent procedural lapse rather than a bar to entitlement. Absence of physical examination did not defeat the claim, since the initial 'Y' selection did not affect Customs' ability to examine the goods. Processing of the MEIS claim was therefore permitted.

Premature IGST-demand proceedings for alleged non-fulfilment of an EPCG export obligation should be left for Revenue consideration in accordance with law. The High Court found no basis to interfere with the CESTAT order holding that initiation was premature. CESTAT observations on revenue neutrality, based on the assessee's data regarding IGST payment and input tax credit, remained subject to Revenue verification and did not bar fresh examination. Revenue may verify the data afresh and decide the matter in accordance with law.

Section 112(a) penalty for an importer's alleged misclassification of removable or exchangeable disc drives was treated as lacking a legal basis where the goods were unavailable at adjudication and no actual confiscation or redemption fine was imposed. The related duty demand and penalties imposed on the importer under the same adjudication order had also been set aside. On these grounds, the Director's penalty for the alleged misclassification was unsustainable and was set aside.

Customs exemption for paver finishers requires the imported machine itself to meet the prescribed paving-width condition when presented for import. Strict construction places the burden on the importer to prove compliance; bolt-on extensions not disclosed in the invoice cannot expand eligibility. The imported machine's undisclosed paving capability constituted misdeclaration, supporting extended-period duty recovery against the importing company. Personal penalty requires a specific allegation and finding of the director's act or omission contributing to the misdeclaration. In the absence of such individualised findings, the director's penalty was deleted, while exemption denial and the extended-period demand remained upheld.

For non-notified goods such as black pepper and socks, the Customs Act places the burden on Revenue to prove their smuggled character before confiscation can be sustained. Failure to discharge that burden means the goods are not liable to confiscation, and penalties imposed solely as a consequence of confiscation cannot stand. The confiscation order and consequential penalties were set aside, with consequential relief.

Financial-institution nominee directors are protected from liability arising merely from their directorship, including good-faith acts or omissions in discharging directorial duties. A nominee and independent non-executive director who had no material relationship or transaction with the company or its management, and no involvement in daily operations, deposit solicitation, or repayment, was not liable for the company's non-compliance with a deposit-repayment order. Criminal proceedings alleging that non-compliance were quashed against that director.

Oppression and mismanagement allegations concerning group-asset and intellectual-property transfers, debt conversion, discounted share allotment and minority dilution require specific findings on the entire material and their cumulative effect; commercial justification cannot replace that inquiry. The dismissal was set aside and the company petition remanded, with status quo over shareholding, assets and liabilities restored pending adjudication. A clean-hands finding denying equitable relief must rest on clear, cogent record-based findings where meeting-related material permits competing interpretations. Perjury directions require precise allegations, meaningful opportunity to respond, identified false statements, reasons, and findings on oath, intentional falsity and requirements for further action; unsupported directions against shareholders and a creditor were set aside.

Restoration of an insolvency application dismissed for non-prosecution can be supported by sufficient cause where former counsel deliberately failed to appear or enable substitution despite a continuing vakalatnama; that default should not be attributed to the litigant. Rule 48(2) of the NCLT Rules prescribes a 30-day restoration period but does not expressly prohibit a later recall request. Section 238A applies the Limitation Act, as far as may be, to insolvency proceedings, allowing Section 5 condonation on sufficient cause. Where the restoration request itself explains the delay, a separate condonation application is unnecessary, permitting merits consideration of the underlying claim.

Regulation 21A deems a secured creditor to have relinquished security where it fails to intimate, within 30 days of liquidation commencement, its election to realise that security. A subsequent Form C claim does not displace this presumption. Where performance bank guarantees securing EPCG export obligations were neither invoked nor renewed, the underlying FDR amounts entered the liquidation estate following the customs creditor's deemed relinquishment. Directions requiring return of the original bonds and remittance of the FDR amounts to the liquidation account were affirmed, and the appeal was dismissed.

Written authorisation and a confidentiality undertaking are required before a suspended director's non-voting representative participates in Committee of Creditors deliberations on commercially sensitive resolution plans. Earlier participation does not waive these safeguards, and no adjournment for later regularisation is mandatory. Resolution-plan materials may be disclosed after the undertaking is received, provided disclosure occurs before voting closes and permits meaningful representations. Committee proceedings and an approved, implemented plan are not to be disturbed for procedural objections absent demonstrated substantive prejudice.

Criminal process cannot serve as a coercive means to recover contractual work dues where allegations remain essentially civil; proceedings brought for that purpose were quashed. Quashing predicate FIRs following settlement or procedural defects does not undermine money-laundering action when scheduled-offence allegations remain pending without merits exoneration. Failure initially to arraign a named developer company is curable, while resale or multiple mortgaging of a fully paid flat may disclose cheating beyond contractual breach. Homebuyer payments for promised construction and delivery can constitute deposits under depositor-protection law. Challenges to provisional attachment should proceed through the statutory adjudication and appellate mechanism.

PMLA attachment of mortgaged land alleged to be proceeds of crime is not displaced solely by a prior mortgage or SARFAESI enforcement. PMLA and SARFAESI operate in distinct fields, with PMLA prevailing on matters of money laundering and proceeds of crime, while attachment does not itself void the prior charge. A secured creditor seeking release must establish bona fides and adequate due diligence, particularly where its interest arose after or around the underlying criminal activity. The FIR registration date does not determine priority if the criminal activity predated the mortgage. Insufficient evidence of due diligence left the land attached and unavailable for auction, subject to a claim before the Special Court under section 8(8).

Capacity-based duty on pan masala packing machines depends on maximum operable packing speed rather than actual production speed. Where a twin-pack FFS machine is modified to pack a single product, the manufacturer's original speed quotation for the twin-pack configuration does not determine capacity after modification. In the absence of reliable material showing that the modified machine could not exceed the lower speed threshold, operation with a single product places it in the higher packing-speed category. Duty is consequently payable under the category for machines operating above that threshold.