Plant-related items, including parts, spares and accessories used for manufacturing-facility modernisation and expansion, fall within the broad definition of capital goods under Notification No. 104/2009-Cus. where they have the required manufacturing nexus. The notification covers plant, machinery, equipment and accessories required directly or indirectly for manufacture, including replacement, modernisation, technological upgradation and expansion. The restriction on components, spares and parts applies only where they relate to capital goods imported earlier; it does not limit imports of capital goods, including accessories, not previously imported. Accordingly, the described imports qualify for the exemption and the duty demand, interest and penalty are unsustainable.

Declared customs transaction values cannot be rejected on third-party investigation material, indicative market data or suspicion without cogent importer-specific evidence of undervaluation. The Revenue must establish a business nexus, parallel invoices, extra consideration, clandestine remittance or comparable incriminating circumstances; similarities with other importers' prices are insufficient. Transaction value remains the primary basis, and enhanced valuation requires a reliable foundation and proper sequential consideration of valuation methods before using the residual method. Contemporaneous imports and the reliability and comparability of price-publication data must be addressed. Operative comparable Tribunal rulings and final appellate assessments concerning the same imports reinforce the requirement of judicial discipline and support rejection of unsustainable valuation enhancements and consequential liabilities.

Export duty exemption for iron ore fines depended on Fe content being below the applicable threshold. Contemporaneous CRCL, Visakhapatnam testing of Customs-drawn representative samples showed Fe content below 58%, corroborated by load-port and discharge-port reports, contractual quality adjustments, and realised export proceeds. A re-test requires objective and legally sustainable grounds and cannot arbitrarily displace reliable contemporaneous evidence. The later CRCL, New Delhi re-test, reported over a year after export, was unreliable because prolonged storage and moisture loss could affect dry-basis Fe determination, and no scientific or procedural defect in the earlier evidence was established. The belated re-test could not support denial of exemption or levy of export duty and cess.

Declared transaction value cannot be rejected on suspicion, unverified third-party import data, uncorroborated statements, or electronic records lacking the required statutory certification and proof of integrity. Uniform loading is unsustainable where the alleged comparable imports are not shown to match the goods in grade, quality, quantity, commercial level, or time. Extended limitation for customs duty recovery requires evidence of fraud, collusion, wilful misstatement, or deliberate suppression with intent to evade duty; prior disclosure and assessment of import details defeat that basis. Where the duty demand fails and no link to a customs offence is established, seized currency and investigation deposits must be released or refunded with applicable interest.

Challenges to seizure of gold and pending customs show-cause proceedings were left for statutory adjudication rather than determined in writ jurisdiction. The Additional Commissioner of Customs was identified as the available forum to determine the parties' competing claims. No view was expressed on the legality of the seizure, the show-cause notice, or the merits. Petitioners were directed to place further material before the customs authority and participate in proceedings, which must conclude by a reasoned order after a fair hearing. The writ petitions were kept pending and adjourned sine die until adjudication is completed.

Pending representations for provisional release of seized imported goods and currency must be considered by the proper customs officer in accordance with law. The claimant may supplement the representations and is entitled to prior notice and an opportunity of hearing. The officer must issue a reasoned decision within three weeks. The merits of the seizure, the provisional release claim, and the challenge to the subsequent seizure memorandum remain open.

Interim stay of an order declaring an earlier advance ruling void ab initio was refused because a stay would revive that ruling despite the impugned finding of misrepresentation of material facts. The scope of the power to invalidate an advance ruling, the alleged misrepresentation, and procedural fairness were identified as issues requiring detailed examination at final hearing. The appeal was admitted for final adjudication, but interim relief was denied.

Provisional attachment under the Prohibition of Benami Property Transactions Act requires the Initiating Officer to form an opinion, supported by a factual basis, that the person in possession may alienate the property during the notice period. Cash and gold already seized and attached by the Income Tax Department remained outside the appellants' control, with no established risk of alienation. The possibility of a future tax adjustment or release did not satisfy this statutory condition. Provisional attachment and its confirmation were therefore unsustainable, without preventing fresh action if a risk of alienation arose after release.

Benami ownership requires affirmative proof that another person provided consideration and that the property is held for that person's benefit; corporate ownership and recorded funds are not conclusive, and the burden remains on the Initiating Officer. Acceptance of an investment as explained in income-tax assessment does not bar benami proceedings, but findings accepting the banking trail, loans and advances must be considered. A benami finding founded on a retracted third-party statement requires meaningful cross-examination and entity-specific examination of documented funding sources. Without these safeguards and independent evidence, the finding is vitiated and requires fresh fact-finding.

A section 148 notice issued on 23 July 2022 for assessment year 2015-16 was described as invalid because notices issued on or after 1 April 2021 for that year fell outside the period permitted by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The reassessment had originated under the earlier regime, followed by proceedings under section 148A and a fresh notice. The text notes that the Revenue conceded the point and that cited decisions supported dropping such notices. Consequently, the notice was quashed and the reassessment could not survive.

Faceless reassessment schemes issued under section 151A require initiation of proceedings, including orders under section 148A(d) and notices under section 148, through automated allocation and the mandatory faceless mechanism under section 144B. A Jurisdictional Assessing Officer cannot initiate such proceedings outside that prescribed mode after the schemes commenced. Departure from the mandatory statutory procedure invalidates the initiation and deprives the consequential reassessment of valid jurisdiction. Accordingly, an order under section 148A(d) and notice under section 148 issued by a Jurisdictional Assessing Officer are illegal, and the resulting reassessment is liable to be quashed.

Additional evidence on the land's distance and agricultural character is relevant to whether it falls within the definition of a capital asset under the Income-tax Act. The purchase deed and valuation report described the land as agricultural, while the distance certificate required verification. The material was admitted for limited verification, with the Assessing Officer required to determine the land's nature in accordance with law after giving the assessee an opportunity of hearing.

Reassessment was invalid where the original scrutiny had examined and accepted the charitable trust's exemption claim, no new tangible material emerged, and the actual recorded reasons were not supplied. Reassessment was also unavailable while scrutiny of a revised return remained pending. Income from sales of books, notebooks and uniforms qualified for exemption under Section 11 where the activity was incidental to the trust's educational objects and the surplus was applied towards establishing a school, without diversion to non-charitable purposes. On materially identical facts, exemption remained available and the excess-income addition was deleted.

Deduction under Section 80JJAA may be allowed where the return, tax-audit report and Form 10DA are filed after the Section 139(1) due date but within the period permitted by Section 139(4). The timing requirement for claiming the Chapter VI-A deduction is treated as directory where the deduction claimed does not exceed the amount certified in Form 10DA. A bona fide delay caused by genuine hardship, including an extended annual general meeting deadline, does not support an adjustment under Section 143(1)(a).

Revenue under the Percentage Completion Method should be recognised only where significant risks and rewards have transferred through legally enforceable sale agreements. Under Accounting Standard 9 and the Guidance Note on Accounting for Real Estate Transactions, mere booking, buyer identification, determination of area or consideration, or receipt of token advances is insufficient. The Guidance Note also requires realisation of at least 10% of the agreement value under legally enforceable documents at the reporting date. Flats with agreements executed later and flats failing that realisation condition should not be included; otherwise, revenue already offered in a subsequent year may be taxed twice.

Clause (iv)(B) of the first proviso to section 80G(5), effective from 01.10.2024, permits a trust that has commenced activities to apply for approval at any time after commencement. Where a delayed Form 10AB application was filed after the earlier extended deadline but rejected after the amended clause took effect, it should be considered under the new regime rather than rejected solely as time-barred under the former filing requirement. The application dated 28.09.2024 is to be treated as an application under clause (iv)(B) and decided in accordance with law.

A consistently employed Project Completion Method cannot be rejected unless statutory conditions are met and true profits cannot be deduced; income and conversion gains must therefore be recognised consistently with that method rather than by sale-agreement dates. Capital gains on conversion of a capital asset into stock-in-trade arise when the converted stock is sold or otherwise transferred. Interest capitalised to project work-in-progress cannot be disallowed on an unsupported estimate where no non-business use or fund diversion is established. Capitalised interest and common-asset costs form part of indexed cost, section 45(2) applies uniformly to the converted asset, and tax deducted at source credit requires verification rather than denial on an assumed timing mismatch.

Excess sugarcane price paid by a co-operative sugar factory to member suppliers under Section 37(1) requires disallowance only to the extent the payment contains a profit-embedded component. The prescribed approach compares the rate paid to members with the commercial benchmark represented by payments to non-members or outsiders, calculates the differential for cane procured from members, and permits reduction where contemporaneous evidence shows that the differential reflects commercial factors such as quality or recovery rather than membership. As the necessary computations and evidence were unavailable, the Assessing Officer must recompute the disallowance using this methodology.

Section 54 exemption remains available where capital gains are invested in a new residential property within the prescribed period, even if they were not deposited in the Capital Gains Account Scheme by the due date under section 139(1). The analysis treats the time available under section 139 as including the extended filing period under section 139(4). Actual utilisation of the capital gains for the qualifying residential investment therefore constitutes sufficient compliance, and failure to make the specified deposit by the original return-filing due date does not defeat the exemption.

Revision under Section 263 was valid because the assessment allowed depreciation on BOT toll-road development cost as an intangible asset without examining the binding CBDT Circular requiring amortisation over the concession period where road ownership does not vest in the assessee. Failure to apply the circular constituted inadequate inquiry. Prevailing High Court decisions also treated BOT-road development expenditure as not creating a depreciable intangible asset, so acceptance of a contrary Tribunal view was not a sustainable possible view. The assessment was therefore erroneous and prejudicial to Revenue interests, supporting revision.