New Delhi, Sep 15 (PTI) JCB India is looking to achieve at least 15-20 per cent growth in exports in the current financial year, the company's MD and CEO Deepak Shetty said on Tuesday. The top company official made the remarks addressing the media on the sidelines of bauma CONEXPO INDIA 2026. "Last year we exported around 14,000 units to several markets, including the developed geographies. The US contributed a major share of our exports," Shetty said. This year, the goal is to achie... ... ...

Roasted areca nuts, whether whole, split or cut, fall under Tariff Item 2008 19 20 as other roasted nuts and seeds. Roasting causes chemical and physical changes and is distinct from drying, dehydration, moderate heat treatment, and permitted preservation or appearance treatments for dried nuts under Chapter 8. Chapter 20 is not excluded because roasting is not a process specified in Chapters 7, 8 or 11. HSN Explanatory Notes to Heading 2008 expressly cover dry-roasted, oil-roasted and fat-roasted areca or betel nuts; the specific entry for roasted nuts and seeds prevails over the general Chapter 8 description.

Alternative appellate remedies do not absolutely preclude writ review under Article 226, as the exhaustion rule is based on policy, convenience and discretion. Writ jurisdiction is available where the decision-making process fails to consider material evidence relevant to the seizure's foundational basis. In customs proceedings, an expert report indicating that seized areca nuts resembled Indian goods required consideration alongside a food laboratory report on human-consumption fitness. An undertaking against human consumption addressed the food-safety concern, making continued detention and refusal of provisional release unsustainable. Provisional release should be granted through the statutory mechanism where material expert evidence has been disregarded.

Limitation for reassessment notice under transitional regime - TOLA - Validity of the reassessment notice for A.Y. 2014-15 issued after expiry of the surviving limitation available under the transitional reassessment regime HELD THAT: - Applying the governing interpretation of the amended reassessment provisions, the old regime and TOLA, the Tribunal held that the extended ten-year limitation operates prospectively. For the relevant assessment year, the old six-year limitation had expired on ... ... ...

House-property loss - failure to consider completion and occupancy certificates - Employees' provident fund contribution - belated remittance House-property loss - failure to consider completion and occupancy certificates - Disallowance of loss under the head "house property" in respect of the multiplex building without consideration of completion and occupancy certificates - HELD THAT: - The appellate authority concluded that the building remained under construction without adverting to ... ... ...

Unexplained income - demonetised currency collected as LIC premium collection agent Addition as unexplained income of demonetised currency deposited by an authorised LIC premium collection agent - HELD THAT: - The assessee acted solely as a recognised LIC premium collection point. During demonetisation, receipt of premium payments in demonetised currency by LIC was authorised; the collected funds were not used by the assessee personally, and no such allegation was made in assessment. The depo... ... ...

Validity of approval under section 153D for search assessment Whether the search assessment could survive where approval was granted in a consolidated and mechanical manner for multiple assessees and assessment years? - HELD THAT: - Section 153D requires approval separately for each assessee and each assessment year. The consolidated approval granted in one go for several assessees and years was not in accordance with that statutory requirement and was fatal to the search assessment proceedin... ... ...

Unexplained cash credit - Proof of nature and source of bank credits - Addition of bank credits claimed to represent rental receipts but treated as unexplained cash credits - HELD THAT: - The assessee failed to furnish documentary evidence substantiating the nature and source of the impugned bank credits as rental income, including particulars of the tenant, the property let out, or a rental agreement. The addition as unexplained cash credit was therefore sustainable. [Paras 4] The addition w... ... ...

Unexplained money - cash deposits during demonetisation - Agricultural income as source of cash deposits Addition as unexplained money in respect of cash deposited during the demonetisation period, despite disclosure of agricultural income - HELD THAT: - The agricultural income disclosed for the relevant year and the immediately preceding year, which had been accepted by the Revenue, explained the source of the bank deposits. The mere fact that cash was deposited during the demonetisation per... ... ...

Reassessment beyond four years - Change of opinion - Fresh tangible material for reopening Validity of reopening for AY 2012-13 where the survey material was available to the AO during the period for initiating scrutiny assessment - HELD THAT: - The Assessing Officer had examined the impounded survey material and recorded statements in post-survey enquiries, and was entitled to select the return for scrutiny until the prescribed period after its filing. Having not done so, reopening beyond fo... ... ...

Assessment of third person pursuant to search u/s 153C - Disallowance of selling expenses Assessment u/s 153C - Assessment of third person pursuant to search - Validity of a regular assessment where the assessee's case was centralised pursuant to a search in another group's cases and the assessment proceeded on the search record - HELD THAT: - Where a specific self-contained mechanism under section 153C governed assessment of a third person consequential to the search, including the s... ... ...

TDS on the payment to a non-resident u/d 195 - Addition u/s 40(a)(i) CIT(A) upheld the addition partly and deleted the remaining on account of being under the category technical services having been rendered and also further observed that the amount confirmed clearly relates to the payments being made a non-technical value, accordingly, held that the provisions of Section 195 are squarely applicable to the facts of the case and the same is not covered by the specified list where payment is no... ... ...

Addition u/s 68 - Unexplained share capital and share premium - Onus to prove identity, creditworthiness and genuineness - Proof of investors' creditworthiness and genuineness HELD THAT: - The assessee did not furnish adequate material regarding the investors, the valuation supporting the share premium, or the sources of investment. The investors had not independently responded, and the material produced did not establish their creditworthiness or the genuineness of the transactions. The ... ... ...

Real income doctrine - Notional accounting entries for event-management receipts and expenses Disallowance of event-management expenditure corresponding to notional budgeted receipts recorded for an event managed on behalf of a foreign company - HELD THAT: - The notes to accounts expressly disclosed that the receipts and corresponding expenditure represented the event budget, while the assessee's actual revenue was only its management fee. Tax is chargeable on real income and not on notio... ... ...

Rejection of exemption claimed u/s 10(38) as long-term capital gain - assessee failed to establish the claim with documentary evidences - Taxability under a development-rights collaboration agreement - Long-term capital gains exemption on sale of shares - appellate deletion of the addition arising from denial of exemption for long-term capital gains on sale of shares was founded on an incorrect factual premise regarding inquiry by the Investigation Wing - HELD THAT: - The Tribunal found that ... ... ...

Software distribution payments to a Singapore supplier - royalty chargeable to tax in India - Disallowance for non-deduction of tax at source - HELD THAT: - Following the Supreme Court ruling [2021 (3) TMI 138 - SUPREME COURT] Tribunal held that consideration paid by a resident distributor for resale or use of computer software under distribution agreements or end-user licence agreements, without any right to use the copyright, is not royalty under the India-Singapore DTAA. Such payment does ... ... ...

Unexplained cash deposits - Cash deposits explained by prior bank withdrawals - Source of cash deposits Addition for cash deposits in the assessee's bank accounts during demonetization, where the stated source was prior withdrawals from the salary and Kisan Credit Card accounts - HELD THAT: - The Revenue did not dispute that the assessee held the Kisan Credit Card account or received salary income. The bank and Kisan Credit Card account statements placed on record supported the explanatio... ... ...

Limitation for reassessment notice under the new regime - Surviving limitation period for reassessment - Whether the reassessment notice issued under Section 148 on 25.07.2022 for assessment year 2014-15 was barred by limitation? - HELD THAT: - Where an earlier notice had been issued under the former reassessment regime and proceedings thereafter continued through the statutory procedure under the new regime, the fresh reassessment notice had to be issued within the surviving time available. ... ... ...

Foreign tax credit - denial of claim on delayed filing of Form 67 - Directory procedural requirement HELD THAT: - The requirement of timely submission of Form 67 for claiming foreign tax credit is directory and not mandatory. Consequently, delay in filing the form could not, by itself, justify denial of the credit claimed. We find no merit in the Revenue's instant argument in light of Deepak Pragjibhai Gondaliya [2025 (6) TMI 1644 - GUJARAT HIGH COURT] having settled the issue that the... ... ...

Alternative statutory remedy under the CGST Act - Exercise of writ jurisdiction Maintainability of the writ petition challenging the show cause notice and consequential order imposing proceedings for issuance of invoices without actual supply and passing of inadmissible input tax credit, despite the statutory appellate remedy - HELD THAT: - The Court held that the petitioner's objections, including the alleged mechanical and predetermined exercise, want of jurisdiction and breach of natur... ... ...