Transfer-pricing benchmarking must separately assess support services rendered on a cost-plus, limited-risk basis and subcontract receipts from a full-risk entrepreneurial segment where separate agreements, functional profiles and risks apply. Their common character as BPO services does not justify aggregation, particularly where separate audited accounts are furnished. The Tribunal rejected aggregation on those grounds. Applying the jurisdictional High Court ruling, the Tribunal also deleted notional interest on delayed receivables because the assessee was debt-free and the Revenue did not distinguish the precedent. The appeal was allowed.

Additional evidence supporting unexplained creditor balances and sales rebates requires verification before the related tax claims are resolved. Agricultural-income exemption and expenditure claims depend on disclosure of agricultural activity, land particulars, sale evidence, agricultural use, and supporting vouchers. Share application money claimed as refunded requires confirmation whether shares were allotted before any reduction is treated as short-term capital gain. Estimated agricultural expenditure should account for assertions that plantation costs were incurred in earlier years and current expenses were limited to maintenance.

Transfer-pricing tolerance under Rule 10CA(7) can apply where an internal comparable produces a single value, since its arithmetical mean remains that value. Where the variation falls within the notified tolerance, the declared price is treated as arm's length. Corporate-guarantee commission may be determined at 0.5% where identical facts and unchanged circumstances support reliance on an earlier determination. Notional interest on outstanding associated-enterprise receivables depends on verifying a uniform policy of not charging interest to third-party export customers; if substantiated by evidence, no interest adjustment should arise.

Where CBDT pecuniary-jurisdiction instructions allocate an assessee's case to an ITO, a scrutiny notice issued by an ACIT without a prior transfer order is beyond that officer's jurisdiction. An assessment founded on that notice is invalid and may be quashed without examination of the merits. The same jurisdictional principle applies where a reassessment notice is issued by an authority lacking jurisdiction over the assessee. Proper allocation and transfer of jurisdiction are therefore essential to the validity of income-tax assessment proceedings.

Customs exemption provisions for apparatus that project or draw circuit patterns can cover photovoltaic-module machinery that strings, arranges, interconnects and protects semiconductor cells in a predetermined electrical configuration; the wording does not restrict drawing to photolithographic exposure or microscopic circuitry. Multilayered solar PV backsheets containing a PVF layer may qualify as sheets with a tedlar base where trade and legislative usage treat tedlar as describing PVF material, without trademark-proprietor authorisation. A differential IGST rate claim on fully declared imports does not itself establish misdeclaration absent concealment, suppression, fictitious documentation, or goods differing from the declaration. Finally cleared goods not secured for production may be unavailable for confiscation, and penalties depend on confiscability.

LCD devices imported for use in manufacturing electricity meters are specifically classifiable under CTI 90138010, rather than as indicator panels under CTH 85312000 or meter parts under CTI 90309010. HSN notes for indicator panels do not cover such goods, and their intended use in meters does not displace an express tariff entry for LCD devices. Accordingly, reclassification as meter parts and associated differential duty and interest cannot stand. Because classification remained disputed until the Supreme Court resolved it, extended-period recovery, redemption fine, and penalties against the importer and Customs Broker are unsustainable.

Stayed disciplinary punishment pending appeal does not, by itself, make an applicant unfit or improper for insolvency professional registration. Where an order removing the applicant from the professional register is kept in abeyance, the applicant remains registered and entitled to perform professional duties; mere pendency of disciplinary proceedings cannot justify refusal of enrolment-cum-registration. The rejection requires fresh consideration without reliance on the pending appeal, while remaining subject to its final outcome.

Failure to pay under a one-time settlement does not create a fresh default for corporate insolvency purposes; a failed settlement restores the original loan position rather than rescheduling it. The recovery-certificate date may therefore govern default, while debt acknowledgments can preserve limitation and prevent the statutory insolvency bar from applying. Incorrect default-date particulars in Form I and other defects that affect neither jurisdiction nor merits may be rectified, including through additional documents. A corporate debtor's asserted viability does not preclude admission without credible evidence of solvency or viability where financial debt and default above the statutory threshold are undisputed. An admission order is reasoned where it records material, contentions, and grounds for admission.

Property of equivalent value may be provisionally attached where property directly or indirectly derived from criminal activity is unavailable because it has vanished or been laundered. The phrase "or the value of any such property" operates as an independent limb of the definition of proceeds of crime, permitting attachment of substitute assets of equivalent value. Such assets may include property acquired before the alleged criminal activity and need not have a direct nexus with that activity. Restricting attachment only to directly traceable proceeds would render the equivalent-value limb ineffective and undermine the statutory objective.

Reverse-charge service tax on foreign-bank charges in export transactions depends on who received the banking service. Where the exporter lacked privity with the foreign bank and export proceeds were routed through an Indian bank, the Indian bank was identified as the service recipient liable under reverse charge. A demand that combined banking charges and overseas commissions without segregation was unsustainable. Audit based on the exporter's records, absence of evidence of mala fide intent, and availability of input tax credit supported revenue neutrality; fraud or suppression could not justify the extended limitation period or equal penalty. The service-tax demand and penalties were set aside.

Retrospective amendment to the definition of wealth-tax assets extends the agricultural-land exclusion to land classified as agricultural in revenue records and used for agricultural purposes. Where agricultural activity is undisputed, the amended exclusion governs the relevant assessment year, including AY 2008-09. Such land falls outside taxable wealth, and tax demand recovered in respect of it may be claimed by refund.

Section 27 of the General Clauses Act, 1897 creates a rebuttable presumption that a postal communication was served when properly dispatched. Where an order-in-appeal was dispatched shortly after issue, an assertion of non-receipt requires credible supporting material to displace that presumption. Failure to pursue the appellate process or make enquiries about the order for nearly two years undermines an explanation for delayed filing. The 820-day delay was treated as inordinate and unexplained, so condonation was refused.

Consent reference of contractual disputes to a sole arbitrator resulted in pending court proceedings being remitted for treatment as an application for interim measures under Section 17. The existing status quo arrangement continued temporarily, subject to the arbitral tribunal's power to extend, vary, or modify interlocutory arrangements. Interim and merits-related issues were to be pursued before the tribunal, with all merits left open.

De novo remand for fresh land identification is unnecessary where sale, conveyance and settlement deeds describe the same extent and identical boundaries, and a differing survey number in one deed is clarified by another. The property's identity may then be determined by construing the instruments together, without a further Court Commissioner's inquiry. Even where a commissioner's report would assist, it may be obtained during appellate proceedings rather than by ordering a de novo trial. The first appeal should instead be determined on its merits in accordance with law.

Further evidence in a money-laundering trial may be placed on record only with prior judicial permission. Proceedings against an additional person may be initiated through a fresh complaint or under the applicable criminal procedure. No determination was made on whether the Enforcement Directorate had breached those procedural requirements. The writ petition was disposed of with liberty to approach the High Court.

Pre-deposit compliance was satisfied because the appellant deposited an aggregate amount exceeding the stipulated statutory requirement. Dismissal solely for alleged non-compliance, without examining the merits, was therefore unsustainable. The appeal requires consideration on merits after the appellant is given an opportunity to present its defence.

Re-export of imported goods retained under seizure during an investigation may be permitted where samples have already been drawn, the goods have remained in custody for a prolonged period, and they have not been cleared for home consumption. Continued seizure serves no useful purpose in those circumstances if revenue interests are adequately secured. Re-export is subject to execution of a bond covering the differential duty and a bank guarantee equal to 5% of the re-determined value.

Comparable Uncontrolled Price benchmarking requires reliable comparable prices and appropriate adjustments under Rule 10B. Consistent annual weighted-average transfer pricing supported by adequate data was not displaced by a monthly average-price approach applied only to transactions producing an adverse adjustment while ignoring lower-price periods; the transfer-pricing adjustment was therefore unsustainable. Deduction under Section 80IE may apply where phased substantial expansion meets the prescribed aggregate investment threshold, without requiring plant-and-machinery additions to be completed within one financial year. Tea estates accepted as eligible in the initial claim year remained eligible in the relevant year.

Failure by an Assessing Officer to record satisfaction during assessment for initiating penalty proceedings for a Section 269SS contravention renders the assessment order erroneous and prejudicial to Revenue interests, permitting revision under Section 263. The Joint Commissioner's power to impose penalty under Section 271D does not remove the assessment-stage satisfaction requirement, and the Principal Commissioner has no corresponding power to levy that penalty. Cash received as unaccounted consideration on transfer of immovable property remains a "specified sum" under Section 269SS, even where it is separately assessed as income; income treatment creates no statutory exclusion.

Outer limitation for completing assessments remains controlling where a Transfer Pricing Officer reference extends the assessment period and Dispute Resolution Panel directions require a final order. The non-obstante clause governing implementation of Panel directions fixes the final-stage period but neither overrides nor enlarges the statutory outer limit. COVID-19 limitation extensions do not apply to original assessment proceedings conducted by tax authorities. Consequently, final assessment orders issued after the applicable outer limitation period for both assessment years were barred by limitation and liable to be quashed.