Brought-forward unabsorbed depreciation is added to current-year depreciation and retains the character of depreciation, allowing set-off against income under other taxable heads. Its availability does not depend on the existence of positive business income. Accordingly, unabsorbed depreciation may be set off against income from house property, consistent with the principle that it can be carried forward and adjusted against other taxable income.

Employee-welfare payments to educational institutions and club expenditure were treated as business expenditure where incurred wholly and exclusively for business purposes. Enabling-facility costs were characterised as revenue expenditure because no capital asset was acquired. Receipts directly connected with setting up a plant were treated as capital receipts reducible from capital work-in-progress. Depreciation on business vehicles and temporary structures was allowed, while a challenge based on additional depreciation was treated as misconceived because the relief concerned consequential differential depreciation. Bad debts, advances and claims written off were allowable. Premium amortisation on foreign-exchange forward contracts used fo.....

Profits from an eligible windmill unit's electricity transferred for captive consumption qualify for deduction under section 80IA. The profit must be computed using the rate charged by the Electricity Board to consumers, rather than the lower rate paid by the Board to generating companies. Payments were not liable to disallowance merely because payees could not be produced after a substantial lapse of time or because expenditure had increased over earlier years. The nature of payees, including labourers, contractors and job workers, and the fact that several payments were below the tax-deduction threshold, precluded treatment of the payments as unexplained. Deduction for captive wind-generated electricity and the payment claims were consequently accepted.

Indexed cost of improvement claimed on flats received under a joint development arrangement requires evidence of actual improvement works and related payments. Construction costs were contractually borne by the developer, and the flats were sold in the semi-furnished condition received from the developer. Quotations and estimates for proposed additional work did not establish material purchases, labour payments, or execution of improvements. The NALA component was also unsupported. Consequently, the claimed indexed cost of improvement was disallowed, and the appeal was dismissed.

Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.

Section 110 distinguishes goods seized for confiscation from documents or things retained as useful or relevant to Customs Act proceedings. The six-month notice period applies to goods seized under Section 110(1), but not to currency treated as a "thing" under Section 110(3) when retained as evidence in an investigation into fraudulent amnesty claims, suspected hawala transactions, illegal gratification, or related offences. Currency is treated as goods where it is itself the subject of a customs violation, such as undeclared cross-border carriage. The return direction was set aside, and the currency was to be deposited in an interest-bearing nationalised-bank scheme pending investigation.

Unjust enrichment does not bar a customs-duty refund where evidence establishes that the duty incidence was not passed to buyers. A Chartered Accountant certificate, Bills of Entry and sales invoices showing bunker oil was sold below its import value supported non-recovery of even the import cost. Once that material was produced, Revenue needed tangible evidence that buyers bore the duty; recording duty as expenditure in the profit and loss account was insufficient. The High Court upheld the finding that the importer had not passed on the duty incidence, so the refund was properly allowed and no substantial question of law arose.

Customs detention of imported goods is synonymous with seizure once the goods are under Customs control and cannot be cleared without permission; a formal seizure memo is only a later procedural step. The six-month period for issuing a show-cause notice therefore runs from initial detention. Any statutory extension of that period must be granted and communicated before the original period expires; a later extension is without jurisdiction. The time-barred extension was quashed and the goods were directed to be released upon an indemnity bond and proof that any sale would be solely for animal-feed use. Classification, duty liability and the goods' nature remain open for adjudication.

Detention of imported goods without complying with statutory requirements for seizure and notice is arbitrary and without legal authority. Even where goods may be prohibited, customs authorities retain discretion to allow provisional release on suitable conditions. Imported betel nut products retained pending classification assessment were directed to be released upon an indemnity bond for their value and a bank guarantee for part of the differential duty, subject to confirmation of fitness for human consumption. Customs authorities may continue adjudication in accordance with law. Demurrage waiver remains for consideration by the appropriate authority upon representation.

Customs show cause notice adjudication must ordinarily be completed within one year under the unamended framework, unless the officer demonstrates that completion was impracticable. The phrase "where it is possible to do so" does not allow proceedings to remain pending indefinitely or for an unreasonable period. Limitation affects jurisdiction, rendering an order passed beyond the applicable period invalid. Although a procedural amendment may generally operate retrospectively, it cannot revive a stale claim; adjudication must also satisfy any extended period available under the amended regime. Unsupported placement in the Call Book does not justify prolonged delay. Unreasonable and arbitrary delay in adjudication violates Article 14 and can invalidate the resulting customs order.

National Industrial Corridor Development Programme implementation prioritises timely infrastructure completion, land allotment, investment mobilisation and commencement of manufacturing. PM GatiShakti-aligned planning requires integrated connectivity, utilities and social infrastructure, while States should resolve land, clearance and SPV-power bottlenecks. BHAVYA proposes investment-ready, plug-and-play industrial parks appraised for ready land, credible demand, connectivity, utilities, realistic phasing and early investor attraction. NICDIT routes Government participation and equity support for BHAVYA project SPVs, and NICDC coordinates implementation and monitoring.

Country of Origin Certificates accepted during customs assessment support preferential duty exemption unless cancelled, revoked, or shown to involve importer collusion. Of 38 certificates for stainless steel imports from Malaysia, one appearing on an unauthentic list was excluded after duty was paid, while the remaining 37 were treated as authentic for exemption purposes. Declared transaction value cannot be enhanced solely by reference to contemporary imports without following prescribed valuation rules or evidence of payment beyond invoice prices. Where allegations of non-genuine origin certificates and undervaluation fail, suppression with intent to evade duty is not established and penalties for misdeclaration or undervaluation do not arise.

Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.

Verifiable evidence of lawful domestic procurement can discharge the claimant's burden for notified gold. Supplier invoices, bank-payment records and GST returns require departmental verification and rebuttal; foreign markings, delayed production of documents and uncorroborated or retracted statements do not by themselves establish smuggling or justify final confiscation. Initial seizure may rest on credible intelligence and reasonable belief, but final confiscation requires proof. Indian currency may be confiscated as smuggled-goods sale proceeds only upon proof of a proximate, identifiable link to specified smuggled goods and knowing dealings. Where these requirements are unmet, confiscation and related penalties are unsustainable.

Foreign-origin gold seized under a reasonable belief of smuggling is subject to a statutory burden of proof requiring the claimant-owner to establish lawful import. Foreign markings, unsupported purchase documents and failure to correlate those documents with the seized bars may establish that this burden remains undischarged, rendering the gold liable to confiscation. Confiscation may be accompanied by redemption on payment of the adjudged fine. A person who knowingly handles, transports or possesses goods known or reasonably believed to be liable to confiscation may incur penalty. Handling and possession of gold found liable to confiscation can therefore support both confiscation-related consequences and a statutory penalty.

Keranat, comprising millet and wheat extracts standardised with sunflower seed oil and containing rosemary extract, is treated as a compound and standardised vegetable extract under Heading 1302. The botanical extracts provide its essential character, while sunflower seed oil acts as a carrier, diluent and standardising medium and rosemary extract as an antioxidant; these additions do not make it a food preparation, medicament or other specifically covered product. As no named extract entry applies within the relevant sub-heading, the residual tariff item for other vegetable extracts applies. Classification under the residual food-preparation Heading 2106 is not appropriate. Keranat falls under CTI 1302 19 39.

SEBI Act offences involving front running must be prosecuted through a complaint filed by SEBI before the competent court, because section 26 bars cognizance on an investor's FIR. Front running involves using non-public information about impending substantial securities transactions to obtain wrongful gains and falls within the specialised securities-market regime. That regime prevails over general penal law where the FIR's allegations essentially constitute the SEBI offence, preventing circumvention through ordinary criminal registration. The FIR was quashed in its existing form, while leaving SEBI free to consider criminal action under the SEBI Act and preserving any independent remedies or distinct IPC/BNS offences.

Frozen funds alleged to be proceeds of crime could not be released under an interim arrangement to meet employee salaries and statutory dues of another company identified as the primary accused. The liabilities were not those of the company holding the frozen funds, and the asserted arrangement between the two companies did not justify their use. The interim direction permitting release was set aside, while the pending appeal before the Tribunal remained open for independent adjudication on its merits and was directed to be decided expeditiously.

Finality of adjudication and judicial discipline prevent revenue authorities from reopening a classification controversy through successive show cause notices where identical facts and issues have already been decided by a competent court and the decision remains operative. Limitation only fixes the period for an otherwise lawful proceeding; it does not create jurisdiction. Revenue may challenge an adverse decision through available remedies and seek interim protection, but departmental review does not suspend its binding effect. Unless stayed or set aside, the decision must be followed.

Disclosure of a field visit report relied upon for cancellation of GST registration is necessary before deciding an application for revocation. A registered person must receive the foundational material and a meaningful opportunity to answer the allegations. Revocation is a substantive statutory remedy, and rejection requires an opportunity of hearing. Procedural fairness also requires specific allegations and disclosure of supporting material; vague assertions do not permit an effective response. Fresh consideration may require supply of the report, an opportunity to respond, and further business-place verification where necessary.