Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.

Revision for inadequate inquiry under section 263 requires a showing that the Assessing Officer's inquiry was inadequate; a different revisional view alone does not satisfy Explanation 2(a). Reassessment initiated on specific information about alleged penny-stock share transactions involved queries and consideration of contract notes, brokerage and ledger records, and bank statements. Acceptance of short-term capital gains as genuine was therefore a plausible view. The reassessment order was not erroneous or prejudicial to Revenue interests, the revision was annulled, and the proposed-addition challenge became infructuous.

High-sea merchant trading conducted through back-to-back USD sales, supported by letters of credit, may justify selecting the foreign associated enterprise as the tested party under the Resale Price Method where the Indian entity bears no significant inventory, collection, market or foreign-exchange risk and has minimal working-capital needs. The associated enterprise's trading margins with unrelated parties can serve as comparable uncontrolled transactions. Steel manufacturers are not functionally comparable to pure merchant traders because their functions, assets and risks materially differ. Currency conversion does not materially affect the analysis where both purchase and sale transactions are denominated in USD.

Expiry of the period for issuing a show-cause notice precluded further departmental proceedings concerning detained gold articles, as additional action would prolong the matter and cause undue harassment. The recorded collective weight of the gold bangle and chain in the release order was corrected. Release remained subject to payment of applicable customs duty and warehousing charges, but those charges were limited to the period ending on the original release order. Release also remained subject to any order passed in a pending Supreme Court SLP.

Natural rubber latex toy balloons are classified under the specific toy-balloon tariff heading rather than residual vulcanised-rubber or general festive-article headings. HSN Explanatory Notes expressly include toy balloons, and General Rule for Interpretation 1 gives priority to the heading that specifically describes their function; a notification clarification supports the same treatment. Deliberately changing classification from the toy heading to avoid BIS conformity requirements, coupled with incorrect exemption use, evidences mala fide intent and supports penal consequences for customs-duty evasion.

Customs valuation rules permit rejection of a declared transaction value where higher National Import Database values for contemporaneous identical goods give reasonable doubt as to its truth or accuracy. Comparable imports must be at the same commercial level, in comparable quantities and from the same country of origin; the lowest comparable value may be adopted. An importer's earlier self-assessed import does not displace such comparables where product specifications are absent from invoices and packing lists. Failure to issue a speaking assessment order does not itself invalidate the assessment where the importer may seek issuance of that order from the competent authorities.

Drawback recovery from an exporter whose goods were shipped under another entity's IEC requires evidence that the exporter actually received the drawback; ICES ordinarily credits the IEC holder's bank account. Recovery is an execution proceeding, but interest liability arises only upon proof of payment to that exporter. Goods already taken outside India are exported goods, not export goods liable to confiscation under section 113, so consequential section 114 penalties fail. Export through another person's IEC may breach foreign trade law, but section 114AA penalties require evidence of knowing or intentional use of materially false customs declarations or documents. The Tribunal set aside recovery and penalties, allowing the appeals with consequential relief.

Foreign customs declarations received through proper channels, with authenticated English translations, attract the statutory presumption for documents received from outside India; absent rebuttal, they may establish import undervaluation. Statements made to Customs officers under summons are admissible because those officers are not police officers, and may corroborate such declarations. The Tribunal held that discrepancies in declared quantity and brand justified rejection of transaction value under the Customs Valuation Rules. Valuation then had to proceed sequentially, and use of identical goods from the same exporter supported redetermination. Differential duty and the mandatory equal penalty for wilful misstatement and suppression were restored.

Residual customs penalty provisions apply only where a contravention, abetment, or statutory non-compliance is established and no separate penalty is prescribed. Penalty discretion must be exercised reasonably, rationally, and proportionately; it cannot justify a mechanical maximum penalty where a bona fide re-export request, unobjectionable goods, unavailable transport, and required no-objections reveal no identified breach. The penalty was therefore set aside. Detention and demurrage arising from Customs-attributable delay in permitting re-export cannot fairly be imposed on the importer or exporter after compliance with re-export conditions. A waiver certificate was directed for charges accruing until the let export order became available.

Re-export of imported goods declared as mixed metal scrap but treated as e-waste warranted substantial reduction of redemption fine and penalty because the goods never entered home consumption. Classification as e-waste rested solely on a Chartered Engineer's report, which was not conclusive evidence for classification. The redemption fine and penalty were each reduced, and the challenge succeeded in part.

Unauthenticated electronic invoices and computer printouts could not establish undervaluation of imported heavy earth-moving machinery. Unsigned invoices did not attract the statutory presumption under section 139, while computer-generated invoices were inadmissible because safeguards for electronic records under section 138C(2) were not met. Statements alleging extra remittances to the overseas supplier lacked independent corroboration and admissible supporting evidence. Substantially identical evidence from the same investigation had already been found insufficient in connected proceedings. The redetermined value, differential duty, interest, confiscation, redemption fine and penalties were set aside, with consequential relief.

Corporate insolvency admission requires the outstanding default on the date of admission to meet the statutory minimum threshold. Part-payments made before admission reduce the debt in default for this purpose, and financial creditors must disclose those payments to the Adjudicating Authority. Where the remaining default falls below the threshold, admission of the insolvency application cannot be sustained. The admission was set aside because pre-admission repayments reduced the outstanding default below the applicable minimum, and CIRP costs were directed to be borne by the appellant.

Judicially fixed interest at 9% per annum on balance loan dues was maintained after the principal and substantial interest had been repaid and the insolvency admission was set aside. Although loan terms ordinarily bind parties, judicial relief may be moulded for the nature and circumstances of insolvency proceedings. Replacing that rate with contractual default interest of 3% per month would have converted closed corporate insolvency resolution proceedings into a recovery mechanism, contrary to the Code's objectives. Supreme Court liberty to seek modification conferred no entitlement to enhanced interest; any contractual claim may be pursued before the forum specified in the loan agreement. The modification application was dismissed.

Transfers of a corporate debtor's funds during the CIRP moratorium are prohibited where made without the Resolution Professional's knowledge, and transferred amounts may be directed to be remitted. Public announcement and publication of CIRP proceedings create deemed knowledge of the moratorium, preventing a recipient from relying on ignorance as a defence. A claim that transferred funds were held in trust requires proof of a trust relationship and a basis for identifying the funds as trust money; an unsupported assertion is insufficient. Proceedings for a moratorium breach may be pursued under Section 60(5) read with Section 14(1)(b). Reliance on Section 74 was unavailable where it was not previously pleaded and had been omitted by the 2026 amendment.

Continuation of a pre-liquidation aircraft sale process is not barred merely because liquidation begins, where the sale had been approved during the insolvency process and was later adopted by the Stakeholders' Consultation Committee. No material irregularity or illegality was established in completing the sale. Former employees could not challenge the transaction on that basis; their entitlement remained limited to recovery of dues under the statutory liquidation waterfall. The challenge to the sale and the related order was dismissed.

Limitation for a personal guarantor's insolvency application begins when the guarantee is invoked. Section 18 of the Limitation Act creates a fresh limitation period only through a written acknowledgment by the party against whom the creditor asserts the right. A personal guarantor cannot rely on unilateral one-time settlement proposals to extend limitation for an application filed by the guarantor; those proposals may operate as admissions usable by the creditor against the guarantor. The Section 94 application was therefore time-barred, and dismissal of both the application and the challenge to the auction notice was upheld.

Under the PMLA, continued freezing or retention of property requires material linking the property to proceeds of crime and a statutory finding that it is involved in money laundering. General allegations of bribery, unconnected to identified transactions or quantified proceeds held by the property holder, do not meet that standard; continued freezing based solely on investigative necessity is unsustainable. Attachment, seizure and freezing may extend to property held by persons not named in the scheduled offence or money-laundering proceedings. Reasons to believe for search or freezing must be recorded, but post-recording communication is not mandatory where the show-cause notice incorporates the relevant reasons. Filing a prosecution complaint does not remove the Appellate Tribunal's jurisdiction over a freezing-confirmation order.

The dispute concerns customs classification of imported unassembled vehicle parts. Customs authorities allege that parts imported in separate shipments should have been declared as completely knocked down (CKD) units, attracting the higher duty applicable to CKD imports, rather than as individual components subject to lower duty. The manufacturer contests the resulting customs demand. Proceedings have been released for fresh hearing before the regular indirect-tax writ bench, with status quo maintained for four weeks.

Canada has imposed retaliatory tariffs on United States-origin industrial and consumer goods following increased United States tariffs on Canadian goods. Effective 8 September, the measures apply at rates of 15%, 25% and 50% across more than 700 products, including steel, aluminium, appliances, dairy products, seafood, furniture, clothing, pulp and paper, and electronics. Existing countertariffs on automobiles remain in force. The measures seek to protect domestic businesses and reduce imports, supported by assistance for affected workers and businesses amid risks to integrated cross-border supply chains.

Foreign-exchange market conditions supported rupee appreciation against the US dollar, driven by stronger domestic equity markets, a weaker US dollar and lower crude oil prices. The USD/INR pair remained broadly range-bound, with oil-price movements and Reserve Bank intervention identified as key near-term influences. The special USD-INR foreign-exchange swap facility for FCNR(B) deposits, overseas foreign-currency borrowings and external commercial borrowings mobilised substantial foreign-exchange inflows.