Section 153C treats the recording of satisfaction, or receipt of seized records by the Assessing Officer of a non-searched person, as that person's deemed search date. Where that event occurs after 1 April 2021, proceedings under section 153C(3) are unavailable and reassessment under section 147 is the applicable route. A consolidated satisfaction note must also identify assessee-specific adverse material and explain its nexus to income alleged to have escaped assessment; generic references to digital devices or electronic evidence do not satisfy this requirement.

Admitted misdeclaration of imported used printers and accessories justified re-determination of customs value, which was sustained. Conditional redemption upon re-export is not permitted under the statutory scheme: where prohibited misdeclared goods cannot be cleared for home consumption and may only be re-exported, redemption fine is unjustified and was deleted. Misdeclaration of prohibited imported goods continues to attract penalty under Section 112(a)(i), although the penalty was reduced because redemption was unavailable. Section 114AA applies to business transactions involving false or incorrect information, rather than only fraudulent exports, and that penalty was sustained.

Interim status quo orders are discretionary protective measures intended to preserve the subject matter pending adjudication. Parties ordinarily should seek vacation or modification before the forum that granted such an order before pursuing appellate interference. In winding-up proceedings, disputed share transfers and the absence of prima facie evidence of active business operations supported preservation of the company's affairs. The status quo direction and arrangements safeguarding company funds continued pending expedited determination of the company petition, and appellate relief was refused.

Section 96(4) of the Insolvency and Bankruptcy Code, effective 26 May 2026, applies retroactively to pending applications under Sections 94 and 95, ending the interim moratorium for personal guarantors from that date. The pre-admission process is procedural, so no vested right arises in interim protection; retroactive operation addresses misuse of that protection. Interim orders in securitisation proceedings require contemporaneous written reasons addressing prima facie case, balance of convenience and irreparable loss. Oral directions cannot support restoration of secured-asset possession. Restraints on auction completion or sale certificates without hearing auction purchasers breach natural justice; the restoration and auction restraints were set aside.

Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.

Indivisible composite construction contracts involving transfer of property in goods and VAT payment under the works-contract composition regime could not be subjected to service tax as erection, commissioning and installation service during October 2005 to March 2007. The applicable Finance Act framework covered service-only contracts and lacked charging and valuation machinery to separate and tax the service element of an indivisible works contract. Constitutional allocation of taxing powers also required exclusion of the goods component. A distinct taxable category for works-contract service was introduced only after that period.

Section 18(2) of the Customs Act requires provisional export assessments to be finalised and the duty payable adjusted before liability for short levy, non-levy or consequential penalties may be considered. A show cause notice and consequential order issued before completion of that process are unsustainable. Investigation material may nevertheless be used while finalising assessments, provided it is disclosed to the exporter and the exporter receives an opportunity to submit a written response and be heard personally. The jurisdictional Assistant Commissioner must complete lawful finalisation before initiating action for duty shortfall or penalty.

Conditional customs duty exemption under an Advance Authorisation requires an Export Obligation Discharge Certificate or redemption letter establishing fulfilment of the export obligation. Proof that an application for the certificate has been made to the DGFT may justify keeping customs action in abeyance until the DGFT decides the application. A duty-payment certificate does not substitute for the required discharge certificate, although it may support an application to obtain one. Demand and penalty relief is sustainable where the discharge certificate is produced, but not where only a duty-payment certificate is available and the certificate remains unissued.

Undisputed substantive eligibility for a Section 80JJAA deduction should prevail over a technical return-processing default where the deduction was allowed in preceding and succeeding assessment years. Denial solely on that processing defect is inappropriate; the jurisdictional Assessing Officer must rectify the CPC intimation and complete a fresh assessment rather than reject an otherwise eligible claim.

Section 69 applies to investments unexplained in the relevant assessment year, not to investments, short-term loans or advances disclosed in audited balance sheets and carried forward from preceding years. Where such amounts are recorded in the books and their existence in earlier years is evidenced by audited financial statements, incomplete supporting details during assessment proceedings do not convert them into unexplained investments of the relevant year. The addition for the disclosed carried-forward investments and advances was therefore unsustainable and required deletion.

Ex parte appellate order was recalled to provide a fresh hearing where the assessee had been unable to appear and a claimed typographical error in the tax audit report remained unaddressed. The recall was treated as necessary to ensure an effective opportunity to be heard, comply with principles of natural justice, and enable proper resolution of the appeal.

Cash deposits alleged as unexplained money under Section 69A require a credible explanation of their source. Handicraft sale proceeds, earlier bank withdrawals and receipts from relatives were treated as plausible explanations based on the deposit and withdrawal details, despite incomplete documentary support. The unexplained-money addition was therefore confined to only part of the deposits, with the remaining addition deleted.

Limitation for penalties arising from contravention of cash-receipt restrictions runs under section 275(1)(c) independently of assessment proceedings, from the first action initiating penalty. A later reference or notice cannot revive an expired limitation period, and COVID-19 extensions do not extend a period that had already expired. Cash advances received by a company through a director acting in a representative capacity are company receipts, not the director's personal receipts. Consequently, penalty liability under section 271D does not attach to the director individually where the transaction and property belong to the company.

Cash deposits claimed as gifts from parents and husband require credible evidence of each donor's financial capacity, not merely confirmation of the gifts. Although accumulated savings remained a possible source, the recorded incomes of the father and husband did not establish capacity for the full claimed gifts, and the mother's income-tax return was unavailable. The explanation was accepted only partly, restricting the unexplained-money addition to half of the deposits.

Cash deposits in the assessee's bank account were explained by registered sale deeds and a cash-flow statement showing receipt of cash consideration on sale of agricultural land and its subsequent deposit. The documentary record established a direct nexus between the sale receipts and deposits. Sale of the land on the date of its purchase did not, by itself, displace that evidence. The unexplained cash-deposit addition was therefore directed to be deleted.

Deduction for donations required no fresh adjudication because the identical claim for the same assessment year had already been allowed in separate appellate proceedings, with a direction to grant the deduction. The pending appeal therefore became infructuous and was dismissed, as no unresolved donation-deduction issue remained for determination in that appeal.

Recorded cash supported by an adequate cash-book balance and an unrebutted explanation of bank withdrawals for business-site expenditure is not unexplained money under section 69A. Cash found in premises partly used for residence does not, by itself, displace recorded balances. Likewise, seized-paper expenditure reconciled with cash-book entries, vouchers and assessment-stage material is not unexplained expenditure under section 69C absent contrary evidence. The appellate authority may verify material already before the Assessing Officer through co-terminous appellate powers. Both additions were deleted.

Income of a statutory urban improvement trust may be exempt from Union taxation under Article 289(1) where the trust operates as an instrumentality of the State. State-controlled constitution and functions, exercise of municipal powers, public governmental character, and transfer of assets and liabilities to a municipal body on dissolution support that characterisation. Although statutory corporations ordinarily have separate legal personality and their income does not automatically constitute State income, the trust's activities were treated as governmental rather than independent commercial operations. Article 289(2) does not apply where those activities are not a trade or business carried on by or on behalf of the State.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where assessment records show specific enquiries and responses on a deduction claimed for CSR expenditure, acceptance of the claim may represent a legally plausible view. Divergent Tribunal decisions on the availability of deduction for CSR expenditure support the conclusion that a contrary preferred interpretation alone cannot justify revision. Revision is therefore unsustainable where the assessing authority adopted one legally plausible view after enquiry.

Cash-deposit additions require de novo factual adjudication where bank statements, a sale deed executed by a joint account holder, and deposit-wise reconciliation support the claimed source as agricultural-land sale proceeds. Treating the explanation as unsupported without verifying the documentary material is inappropriate, particularly where the assessment was completed without the taxpayer's participation. Verification of the asserted source must precede determination of the cash-deposit addition.