Interest on refunded redemption fine is governed by restitution principles where confiscation is set aside. Redemption fine paid for release of confiscated goods becomes a revenue deposit, not a customs duty refund; therefore, the delayed-refund mechanism under Section 27A, which runs from the refund application date, does not apply. Compensatory interest is payable for the full period during which the Department retained money not legally due. The assessee is entitled to interest at 12% per annum from the date of deposit of redemption fine until its actual refund.

Foreign customs declarations obtained through official investigative channels and supported by authenticated translations attract a statutory presumption of correctness unless rebutted. Objections based on copies or absent signatures, stamps, or original-language documents do not displace that presumption without contrary translation or evidence. Voluntary statements to Customs officers and discrepancies in quantity or brand can corroborate import undervaluation. Such misdeclaration permits rejection of the declared transaction value under the valuation rules, followed by sequential redetermination using values of identical goods from the same exporter. Wilful misdeclaration and undervaluation support differential-duty liability and an equal penalty under the applicable customs penalty provision.

Drawback recovery, including interest, requires evidence that the sanctioned amount was actually credited to the relevant IEC holder's bank account; where no shipping bill used that IEC, recovery cannot be sustained. Penalties for export-related confiscation require an act or omission rendering goods liable to confiscation while they remain export goods; garments already removed from India cannot be treated as confiscable export goods for that purpose. Penalties for false declarations also require proof that the person knowingly or intentionally made, signed, used, or caused use of a materially false customs document. In the absence of such evidence, the drawback recovery and penalties fail.

Customs valuation may be redetermined after rejection of the declared transaction value under Rule 12 where reliable contemporaneous comparable-import data creates reasonable doubt. Rule 5 permits reliance on imports at the same commercial level, quantity and country of origin; the lowest reliable comparable value may be adopted where no material difference in goods or specifications is established. A prior self-assessed import that is not contemporaneous does not provide a valid comparator. Separately, a remanded Bill of Entry assessment requires a speaking order and personal hearing under Section 17(5); failure to issue that order calls for implementation of the remand direction rather than quashing the assessment.

Natural rubber latex toy balloons fall under Customs Tariff Heading 9503 where their specific functional coverage as toys is supported by the HSN Explanatory Notes. Under the General Rules for Interpretation, a specific heading and applicable notes prevail over a general, material-based residual entry such as Heading 4016; Heading 9505 for festive or carnival articles does not cover latex toy balloons. Notification No. 02/2021-Customs also clarifies this classification. Altering shipping-document classifications, seeking to avoid BIS requirements, and incorrectly claiming customs-duty exemption may establish mala fide intent, supporting differential-duty recovery and penalties for wilful misclassification.

Post-export amendment of shipping bills under Section 149 of the Customs Act is permissible where contemporaneous documentary evidence supports the amendment under the law applicable at export. A later-introduced limitation period cannot apply retrospectively, and repeated "NO" declarations, delay, or potential fiscal benefits do not create an absolute bar, although they may affect discretion. Amendment does not itself grant MEIS benefit, which requires independent determination by the competent authority. Departmental customs appeals below the prescribed monetary threshold are not maintainable unless a specified exception applies.

Expiry of the maximum statutory period for issuing a show-cause notice under the Customs Act, 1962 makes continued detention of seized goods impermissible, including where the permitted extension period has also elapsed. Further proceedings concerning the seized gold articles cannot continue, and their release remains subject to applicable customs duty and warehousing charges. The seizure particulars record the collective weight of the gold bangle and chain as 233 grams. Warehousing charges are payable only up to 26 November 2025, calculated at the rates applicable on the detention date.

Transferable advance licences allegedly obtained through misrepresentation or fraud raise questions on whether imports remain valid until the licensing authority suspends or cancels the licence. Key issues include the licensing authority's power and duty to cancel fraudulently obtained licences, customs duty liability of transferee importers relying on endorsed licences, and exposure to confiscation and penalties for acts or omissions rendering imported goods liable to confiscation. The scope of penalty under the Customs Act is considered in relation to imports made under licences later alleged to have been obtained fraudulently.

Release of seized gold jewellery was linked to the statutory requirement of a show-cause notice before confiscation, including issues of waiver of notice and personal hearing under Section 124. The special leave petitions challenging non-compliance with that requirement were dismissed because a coordinate Bench had dismissed an identical special leave petition. The dismissal left the challenged position undisturbed without setting out any further substantive determination on the notice, confiscation, or waiver issues.

Property purchased by a father in the names of his minor children falls within the child exception under the Prohibition of Benami Properties Act where the 2016 amendments apply retrospectively as declaratory, procedural, curative and machinery provisions. The father-minor child relationship also constitutes a guardian-ward fiduciary relationship under the unamended fiduciary-capacity exception. Consequently, a suit asserting rights in such property is not barred by the Benami law and the plaint is not liable to rejection.

Transfer-pricing benchmarking under the Resale Price Method permits an associated enterprise to be selected as the tested party where it is the less complex entity and reliable margins from comparable uncontrolled transactions are available. Merchant-trading transactions involving back-to-back USD purchases and sales, letters of credit, insignificant working-capital needs and limited inventory, credit, market and foreign-exchange risks supported that selection. A single material comparable invoice may be used under Rule 10B(1)(b). Manufacturing comparables with materially different functions, assets and risks were unsuitable, resulting in acceptance of the Resale Price Method analysis and no adjustment beyond the taxpayer's voluntary adjustment.

Faceless reassessment jurisdiction under Section 151A requires a notified scheme authorising faceless assessment, reassessment and issuance of income-escaping assessment notices. Where the notice under Section 148 and consequential statutory, show-cause and reassessment proceedings were initiated and substantially conducted before notification of the e-Assessment of Income Escaping Assessment Scheme, 2022, the statutory authority to proceed facelessly was unavailable when jurisdiction was assumed. Passing the reassessment order after notification does not cure that defect. Such proceedings and the resulting reassessment order are void ab initio and bad in law.

Separate transfer-pricing adjustment for interest on overdue receivables from an associated enterprise may be warranted even where the underlying IT-enabled services transaction falls within the arm's-length tolerance range. Receivables representing an abnormal credit period beyond the contractual 90 days require independent consideration where the credit-period impact is not adequately reflected in the service price. The principle that receivables are closely linked to the principal transaction applies only when, after a credit-period adjustment, the transaction price remains at or above the arm's-length price. Interest beyond the agreed credit period may therefore be benchmarked at LIBOR plus 200 basis points.

Repayment of recorded micro-finance loan receivables, supported by audited disclosures, cash-book entries, cash-flow details, deposit particulars and borrower confirmations, does not create a fresh unexplained cash credit. Receipt in demonetised currency and non-service of some third-party notices do not establish undisclosed income without material disproving the repayments, particularly where the books and loan portfolio remain unrejected. Interest embedded in the instalments, already credited in the books and offered to tax, cannot be separately added once the principal recoveries are accepted; such addition would duplicate taxation.

Section 80-IA(8) requires inter-unit transfers to be examined at market value when computing profits of an eligible cogeneration undertaking. Low-pressure steam extracted and supplied to a paper division remains a commercially useful, measurable output of the integrated process, carrying common fuel, boiler, labour, maintenance, depreciation and related costs despite requiring no additional fuel after extraction. Assigning nil cost to that steam and charging all common costs solely to electricity revenue is impermissible without determining an alternative market value or identifying defects in the recorded value. Where verified records support the disclosed allocation, the eligible undertaking's reported profit and resulting section 80-IA deduction are to be accepted.

Reassessment initiated for alleged escaped capital gains cannot be sustained solely on additions for notional annual letting value or reclassification of disclosed rental income when no addition is made to the income forming the basis for reopening. Where the assessee was only a confirming party to a transfer of tenancy rights, neither transferred immovable property nor received consideration, and the alleged capital gains were not assessed, the Assessing Officer cannot uphold reassessment through unrelated income-from-house-property additions. The reassessment was therefore without jurisdiction and quashed in favour of the assessee.

Reassessment beyond three years requires satisfaction of the statutory escaped-income threshold and approval from the competent higher authority. For assessment year 2019-20, the recorded escaped income was below the threshold required to invoke the extended reassessment period, while approval was granted by an authority not competent after the three-year period. These discrepancies showed non-application of mind, invalidated the sanction, and rendered the reassessment notice and consequential assessment void.

Revisionary jurisdiction cannot be exercised where a reassessment has specifically examined alleged penny-stock share transactions and accepted the returned short-term capital gains after verification. Contract notes, broker and ledger details, bank statements, and other supporting material established that the Assessing Officer had conducted inquiry and considered the evidence. The assessment represented a plausible view based on inquiry and verification; therefore, it was neither erroneous nor prejudicial to the interests of the Revenue. The deeming fiction applicable to cases lacking inquiry did not apply, rendering the revision order unsustainable.

Foreign-currency loans repayable in US dollars are benchmarked by reference to LIBOR, with LIBOR plus 300 basis points treated as appropriate. Under the transactional net margin method, comparable companies require meaningful functional and product comparability; entities engaged in distinct engineering procurement and construction activities or manufacturing materially different products should be excluded. No separate arm's-length interest adjustment arises on delayed associated-enterprise receivables where no interest is charged to related or unrelated parties and margins are embedded in pricing. Section 14A read with Rule 8D does not permit a disallowance where no exempt income is received or accrues during the relevant year.

AMP expenditure included in operating costs for interconnected international transactions benchmarked under TNMM cannot be separately subjected to an arm's-length adjustment where accepted net margins already absorb that cost; separate benchmarking without proper segregation would distort the selected method, and the Bright Line Test does not support a protective adjustment. A separate interest adjustment on outstanding receivables requires verification of whether working-capital adjustments already reflected the impact, to prevent duplication. A mismatch between returned income and Form 26AS receipts requires factual examination where receipts are claimed to belong to associated enterprises, including evidence relating to their Indian assessment and mutual agreement procedure.