For customs valuation, the price actually paid by the subsequent importer under its direct contract with the overseas supplier is the transaction value where the parties are unrelated and price is the sole consideration. The original importer neither honoured the letter of credit nor took delivery, so its contract did not result in a completed sale or payment. As the subsequent importer paid the renegotiated price, obtained title and clearance, and no additional consideration or basis to reject the declared value existed, the declared price is to be accepted as the assessable value. The transaction-value regime applicable to the import could not be displaced by the earlier deemed-value approach.

Social Welfare Surcharge is not payable on imports made against MEIS or SEIS duty credit scrips where Basic Customs Duty is fully exempt under the applicable customs exemption notifications. As the surcharge is calculated as a percentage of aggregate customs duties payable, it is nil where the aggregate customs duty is nil due to exemption. It cannot be computed on a notional Basic Customs Duty. This position applies to exemptions under Notifications No. 24/2015-Customs and 25/2015-Customs, with consequential refund relief available for surcharge paid.

Extra Duty Deposit collected in related-party imports pending final assessment or valuation verification is a security, not a statutory customs duty levy. It may be appropriated only where final assessment establishes an additional duty liability. If the declared transaction value is accepted and no further duty is payable, the basis for retaining the deposit ends. The limitation applicable to refunds of customs duty does not govern return of the deposit, so its refund after final assessment is not time-barred.

Classification and duty consequences of imported sorbitol under the Advance Authorisation Scheme require fresh adjudication where import documents reflected a different tariff heading due to an admitted supplier error. Sorbitol was claimed under Chapter 2905 for use in providing moisture to paste, while certain documents showed Heading 382460. The claimed fulfilment of export obligation and cited decisions concerning departmental challenge to goods imported under the scheme must be considered. The classification and consequential duty dispute is remitted for reconsideration after considering the cited decisions and further submissions.

SAFTA preferential-duty entitlement remains available where an undisputed, valid Certificate of Origin confirms that goods were wholly produced or obtained in the exporting State and the prescribed origin-verification procedure has not been followed. A purported relinquishment of that claim, obtained amid customs detention, demurrage and urgent clearance requirements, does not constitute voluntary relinquishment or prevent challenge to reassessment. Denial of the preference consequently cannot support differential duty or interest. Where examination reveals no discrepancy in quality, classification or valuation, goods are not seized, and no misdeclaration or fraud is established, confiscation, redemption fine and penalty lack a sustainable basis.

Truthful baggage declaration under Section 77 is a condition for detention and later return or re-export under the special passenger-baggage regime in Section 80. Section 125 provides a general discretionary redemption power for confiscated prohibited goods on payment of fine, but does not create an independent right to re-export or override the declaration and detention requirements. Permitting re-export of undeclared gold under Section 125 would defeat the safeguards in Sections 77 and 80. Where the passenger crossed the Green Channel without declaring the gold or seeking detention, re-export could not be granted; revisional correction of an erroneous re-export direction was within the revisional power.

Confirmation of attachment of bank funds as alleged benami property could not rest on an incomplete investigation. The material did not establish that the appellant supplied demonetised currency to the alleged benamidar companies, while their actual control, incorporation, shareholding, bank operations, management and third-party dealings remained unverified. The appellant's bullion-sale explanation also required verification because stock registers, VAT returns and supporting sale documentation were not produced. The attachment confirmation was therefore unsustainable on the existing record, and the matter was remanded for comprehensive re-investigation.

Benami ownership was established for the identified shares through cumulative circumstantial evidence: the apparent holder lacked financial and operational capacity, purchase funds came through broker-connected entities, repayments were funded by promoter-group entities, and no independent commercial source was substantiated. The individual was therefore treated as beneficial owner and the company as benamidar, sustaining attachment of those shares. Freezing of additional shares was invalid because the provisional attachment, notice and impugned order did not cover them or identify them as benami property; their release to the rightful owner was directed. Attachment cannot extend beyond property specifically covered by statutory proceedings.

Reassessment initiated beyond three years from the end of assessment year 2016-17 required sanction under section 151(ii) from the Principal Chief Commissioner, Principal Director General, Chief Commissioner or Director General. Approval for the section 148A(d) order and section 148 notice was granted by the Principal Commissioner, who was not the prescribed authority. The defective sanction invalidated the reassessment initiation; the reassessment proceedings were therefore vitiated and quashed in favour of the assessee.

A reassessment notice under Section 148 for assessment year 2015-16, issued after 1 April 2021, was treated as invalid where it could not be completed within the period prescribed by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The Revenue had conceded that such notices must be dropped, and the notice issued on 26 July 2023 fell within that concession. Decisions applying the concession to identical facts were considered applicable, with no contrary authority identified. The notice was quashed.

Registration under section 12AB and approval under section 80G require verification of the genuineness of an applicant's activities. A prior remand for fresh examination does not require grant solely on self-attested material already filed. Failure to provide requested records concerning educational activities, approvals, accounts, staff payments, fees and donations may justify inability to verify genuineness. Where non-compliance resulted from the applicant's mistaken belief that no further documents were required after remand, the applications may be restored for fresh consideration with a further opportunity to submit relevant self-attested or self-certified documents.

Interest earned on compulsory statutory deposits with co-operative banks is attributable to a co-operative society's business of providing credit facilities to its members. Where deposits are mandated by the Karnataka Souharda Sahakari Act, 1997, the interest constitutes business income eligible for deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961. Treating such interest as income from other sources is inconsistent with the principles applicable to compulsory statutory investments.

Where rectification establishes that no tax demand survives, the Tribunal may use its inherent appellate powers to direct refund of tax recovered while the rectification application was pending. The rectification granted the claimed tax deducted at source credit and calculated a refund after adjusting the recovered amount; a further refund remained due even without that adjustment, showing that the original demand had been extinguished and the recovery amounted to duplicate collection. Such relief may be necessary in exceptional circumstances to prevent arbitrary recovery from frustrating the statutory appellate process.

CSR payments to institutions meeting the prescribed conditions remain eligible for deduction under section 80G because, although Explanation 2 to section 37(1) excludes CSR expenditure as business expenditure, section 80G contains no corresponding exclusion for qualifying CSR donations. Separately, for a continuing block of building assets, written down value must be reduced by actual sale consideration as the moneys payable under section 43(6)(c). The stamp-duty valuation fiction under section 50C is confined to capital-gains computation and cannot be extended to depreciation or written-down-value computation without express legislative provision.

Allowability of a bank-guarantee amount reported as a contingent liability in Form 3CD requires verification of the underlying accounting entries, whether reporting was gross or net, the amount's nature, and its connection with other years before an adjustment can be sustained. Cash-paid electricity expenses require verification of payment circumstances, installations, banking access and the claimed Rule 6DD exception before disallowance under Section 40A(3). Both issues were remanded for fresh factual determination after reasonable opportunity to present relevant material.

Approval under section 153D must be separately accorded for each assessment year, even where proceedings concern the same assessee. A single combined communication approving assessments for multiple years does not meet this requirement. Consequently, combined approval for ten assessment years was treated as invalid, and the resulting assessments were quashed in favour of the assessee.

Rental income from leased properties is assessable as income from house property where the facts do not show that commercial exploitation through letting is itself the assessee's business activity. The ITAT Delhi noted that the assessee had returned the receipts under that head, claimed the statutory standard deduction, and carried on trading-related activities rather than a property-letting business; it directed recomputation accordingly. The objection that limited scrutiny had been impermissibly converted into complete scrutiny failed because the record established selection for complete scrutiny.

Reassessment notices issued after expiry of the surviving limitation under the substituted reassessment regime, read with TOLA, are described as void and incapable of supporting a consequential reassessment. The text states that TOLA did not extend the applicable limitation in the stated circumstances, rendering the notice time-barred. It also explains that sale receipts treated as unexplained cash credits cannot remain included in turnover used to compute returned income, as this may create a double addition. The accounts require fresh verification of transport records and payment details, followed by recasting of turnover and income without duplication.

Income cannot be estimated solely from a decline in profit ratio where regularly maintained audited books, including sales, purchases and stock records, are accepted and not rejected under section 145(3). Reduced profitability supported by seasonal business conditions, adverse crop conditions, sales returns and exceptional prior-year margins does not justify a low-profit addition without contrary material. Dealer scheme expenses are allowable where scheme details, dealer-wise and transaction-wise workings, credit notes, invoices, ledgers, confirmations, and evidence of settlement or reversal establish that the liability crystallised and directly related to relevant-year sales. Unsupported doubts cannot displace substantiated accounting treatment.

Corporate social responsibility expenditure disallowed as business expenditure under section 37(1) may nevertheless qualify for deduction under section 80G when the statutory conditions are met. Section 80G operates separately at the total-income computation stage under Chapter VIA, and a statutory obligation to incur CSR expenditure does not negate the voluntary character of a donation where the donor receives no reciprocal benefit. Denying section 80G relief solely because the payment formed part of CSR expenditure would create a double disallowance. The deduction is available subject to computation in accordance with law.