Customs-clearance facilitation, including handling import documents, instructing a Customs Broker, paying assessed duty, and arranging examination, clearance and transport, does not by itself establish beneficial ownership, authorised agency, or knowing participation in misdeclaration. Differential duty and consequential interest cannot be imposed without foundational facts proving ownership, express or implied authorisation by the importer, or knowledge of concealed goods and false documentation. Penalty for duty evasion requires proof of collusion, wilful misstatement or suppression, while penalty for false documents requires knowing or intentional use of materially false documentation. In the absence of those statutory ingredients, duty liability, interest and penalties cannot be imposed on the facilitator.

National Litigation Policy exceptions must be raised before the High Court to be relied upon in a Special Leave Petition. Failure to urge the purported exception at the High Court stage resulted in the Special Leave Petition being declined, as the ground was not available for consideration at that later stage.

Approval of a Port Trust as custodian of an imported-goods customs area under Section 45(1) of the Customs Act is valid where the Major Port Trusts Act imposes no corresponding customs-duty liability for pilferage. The Port Trust's bailee-like civil liability to goods owners for loss, destruction or deterioration is distinct from its statutory liability to Revenue under Section 45(3). Section 13 relieves the importer of duty on pilfered goods, while Section 45(3) places that liability on an approved custodian. Customs-duty liability therefore arises only for pilferage during the period of valid approval, not before notification.

Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue; collecting material without a conscious enquiry, legal analysis or reasoned view does not satisfy that standard. Interest on compensation or enhanced compensation is charged as income from other sources on receipt, with only the prescribed deduction, and agricultural-land capital-gains exemption does not displace that scheme. Faceless assessment is procedural and does not alter jurisdiction determined by the jurisdictional Assessing Officer. Reopening approval, alleged defects in an operative assessment order, audit objections or an Assessing Officer's proposal do not preclude revision where the Principal Commissioner independently examines the record and forms the required satisfaction.

PAN status declared in the PAN application and used in filed returns may be used by CPC for limited prima facie processing under section 143(1)(a); substantive correction of an entity's tax status lies outside that automated process. A Delaware limited partnership's Indian tax characterisation requires examination under Articles 3 and 4 of the India-USA DTAA, including corporate treatment, US fiscal transparency, and whether income is taxed to the entity or its partners. That determination affects short-term capital-loss carry-forward and return-filing timing. Departmental records must also be checked where electronic communication is claimed to have been sent to an email address not furnished by the taxpayer.

Rejection of books of account and profit estimation require demonstrated defects in the audited accounts and reliable supporting material; an unsuitable comparison with a substantially larger real-estate entity does not establish unreliability where project-specific tenant-rent expenditure and project-completion accounting apply. Alleged sales below ready reckoner value require comparison with the valuation applicable on the booking date and complete, unrebutted sales data. A survey statement made before the financial year closes cannot displace audited accounts without corroboration. Cash transactions relating to earlier years and covered by an Income Declaration Scheme disclosure require appropriate linkage and credit where the redevelopment project is the sole relevant project.

Deemed concealment under Explanation 3 to Section 271(1)(c) may arise where an original return is not filed without reasonable cause, but the tax sought to be evaded must be computed under clause (c) of Explanation 4. Tax deducted at source before issuance of reassessment notice under Section 148 must reduce the relevant tax amount. Where returned income is accepted without adjustment and pre-notice tax deducted at source exceeds the final assessed tax liability, no tax is sought to be evaded. Penalty under Section 271(1)(c) was therefore deleted.

Penalty for furnishing inaccurate particulars requires an independently established default; a statutory disallowance alone is insufficient. A professional-fee debit corresponding to loan repayment and matching professional receipts was revenue neutral and could not support penalty where it was treated as a loan transaction rather than unexplained credit. Penalty remained applicable to professional-fee claims for which recipients denied payment or supporting evidence was not provided. For tax-deduction disallowance, an individual's or HUF's obligation to deduct tax depends on preceding-year gross professional receipts exceeding the prescribed threshold. Unverified reliance on receipts from an earlier year did not disprove the claimed absence of that obligation, so penalty could not rest on that disallowance.

Enhanced leave-encashment exemption under Section 10(10AA)(ii) is stated to apply to a non-government employee retiring in assessment year 2020-21. Notification No. 31/2023 raised the notified exemption ceiling from Rs. 3 lakh to Rs. 25 lakh. The enhancement is characterised as a beneficial and remedial measure that rationalises the existing exemption, mitigates hardship and addresses disparity with government employees. On that basis, it is construed liberally to extend to pending proceedings despite no express retrospective provision, making the employee's leave-encashment receipt fully exempt within the enhanced limit.

Interest deduction under Section 43B requires loan-wise evidence linking accrued term-loan interest with payments made before the return-filing due date. Consolidated financial statements, ledger accounts and bank statements may not establish that nexus; primary payment evidence, including a bank certificate, may require fresh verification. Expenditure disallowance under Section 14A read with Rule 8D does not arise where no exempt income was earned during the relevant previous year. Accordingly, the interest claim remains subject to factual verification, while the exempt-income-related disallowance is unsustainable.

Rectification or recall under section 254(2) is unavailable where alleged non-consideration concerns a coordinate-bench order that was not available at the hearing and was not specifically relied upon in the grounds or Tribunal record. Failure to consider a jurisdictional High Court judgment may support rectification in appropriate circumstances, but that principle does not permit review of an earlier order through section 254(2). The alleged omission therefore did not constitute an error apparent from the record, and the assessee could not obtain rectification or recall.

Limitation for a rectification application under section 154(7) commences when the intimation is communicated to the assessee, rather than on the date appearing on the intimation. Where the assessee did not receive the intimation and became aware of the demand only through recovery proceedings, limitation cannot be calculated solely from the intimation date. The rectification application therefore could not be rejected as time-barred on that basis; the delay was condoned and the matter was restored for adjudication on merits.

Reversal of opening accrued or unbilled revenue is allowable where revenue was consistently recognised on the mercantile basis according to work performed, offered to tax on accrual, and retained as an asset until billing. Amounts reversed on subsequent billing, including earlier-year billing adjustments, do not create fresh taxable income where they were already recognised and taxed. Professional fees paid to non-resident member firms do not attract withholding-based disallowance where the payments are not consideration for protected rights, know-how, or information constituting royalty under the applicable tax treaties, and the recipients have no permanent establishment in India. Consequently, disallowance for non-deduction of tax is not sustainable.

Recurring trademark fees paid under a non-exclusive, time-bound licence are allowable as revenue expenditure where the licensor retains exclusive ownership and the user acquires only a limited contractual right to use the mark. Annual fees calculated as a percentage of gross profit, coupled with an obligation to stop using the trademark on termination, do not create proprietary rights, exclusive commercial rights, or an enduring capital asset. The payments are operational expenses deductible under Section 37(1) of the Income-tax Act, 1961.

Penalty for under-reporting of income under section 270A cannot be sustained where the notice and penalty order fail to identify the specific clause of section 270A(2) allegedly breached. General references to under-reporting create ambiguity and invalidate the penalty proceedings. Penalty is also unwarranted where relevant receipts were disclosed and non-taxability was claimed on a bona fide legal position. A rejected claim or addition arising from debatable questions concerning royalty, business income, permanent establishment or profit attribution does not justify penalty absent concealment or non-disclosure of material facts.

Section 153C requires the Assessing Officers of both the searched person and the other person to record jurisdictional satisfaction. Assessment limitation runs from handover of seized material, and a later satisfaction record does not invalidate proceedings absent breach of a prescribed timeline or demonstrated prejudice. Cross-examination and supply of a third party's statement are required only when the statement underpins an adverse addition; seized spreadsheet evidence and corroborating transaction data may instead support the addition. A satisfaction note need not finally quantify undisclosed income. Where electronic records support cash consideration for jointly acquired property, the addition requires recomputation according to the assessee's verified ownership share.

Failure to satisfy the conditions for the concessional corporate tax regime under Section 115BAA requires computation at the applicable normal rate. Where a company's turnover in the relevant preceding financial year did not exceed the prescribed threshold, its income is taxable at the normal corporate rate of 25%, rather than 30%. Denial of the concessional rate does not itself trigger the higher normal rate; the applicable ordinary rate remains determined by the turnover-based condition.

Comparable Uncontrolled Price (CUP) Method may benchmark exports to associated enterprises where independent purchases provide reliable comparables and material differences can be adjusted; unsubstantiated objections based on geography, volume or timing do not displace CUP. TNMM may be unreliable for a first-year producer without meaningful capacity-utilisation adjustments. Foreign-currency borrowings require currency-specific arm's length benchmarking that accounts for tenure, security, credit and market risks; a uniform LIBOR spread without comparables is insufficient. Delayed foreign-currency receivables constitute a separate international transaction, with interest benchmarked at LIBOR plus 200 basis points after a 60-day credit period rather than domestic deposit rates. Transfer-pricing relief applies to export sales and external commercial borrowings.

Reassessment notices issued more than three years after the relevant assessment year require material revealing escaped income of at least Rs. 50 lakh and prior sanction from the higher specified authority. These conditions are mandatory for assuming reassessment jurisdiction. Where the alleged escaped income was below that threshold and approval came from the Principal Commissioner rather than the authority prescribed for delayed notices, jurisdiction was not validly assumed. The reassessment notice was invalid, and the consequential assessment was quashed.

Professional banking education provided to an identifiable section of the public constitutes educational charitable activity for Section 2(15); the general-public-utility proviso does not apply, and refusal of approval under Section 10(23C)(vi) does not determine entitlement to Section 11 exemption. Interest on tax-free bonds is consequently governed by the charitable-institution computation regime under Section 11 rather than Section 10(15). Section 11(6) cannot support a depreciation disallowance where no depreciation was claimed. Accumulation under Section 11(2) is permissible where Form No. 10 identifies definite purposes, including premises, e-learning facilities, and testing, learning and data centres, rather than merely repeating general institutional objects.