Customs-duty exemption applies to goods imported into an SEZ unit for authorised operations under the SEZ Act. Duty becomes chargeable only when goods are removed from the SEZ to the Domestic Tariff Area, using the rate and valuation applicable at removal. Goods retained in an FTWZ for intended authorised operations cannot be subjected to a differential-duty computation merely to require a bank guarantee for provisional release. A bank guarantee based on such duty is therefore unsustainable; provisional release may instead be secured by a bond equal to the value of the goods. Customs duty arises upon clearance of manufactured goods from the SEZ to the Domestic Tariff Area after authorised operations.

Low-ethoxylated non-ionic fatty alcohol ethoxylates fall outside the tariff category for organic surface-active agents where they do not satisfy the cumulative Chapter 34 water-solubility and surface-tension conditions. A product must form a transparent or translucent liquid or stable emulsion without separation of insoluble matter and reduce surface tension to the prescribed level. Chemical testing showed a translucent liquid separating into two layers, failing the required water-solubility condition. Water-insoluble surface-active products are therefore classified as miscellaneous chemical products under tariff items 3824 9090/3824 9990 rather than under tariff item 3402 1300, rendering the consequential differential duty, confiscation, interest and penalties unsustainable.

Voluntary disclosure and rectification of an omitted supplier invoice shortly after customs clearance can establish a bona fide declaration error rather than duty evasion. Where the importer seeks reassessment and pays differential duty before departmental detection, and the supplier's communication supports the inadvertent omission, a residual customs penalty is not justified without evidence of wilful non-compliance or intent to evade duty. Penalty under the residual provision is therefore unsustainable in the absence of mens rea.

Notified gold under the Customs Act places the burden on persons in possession to establish lawful procurement and transportation. Absence of licit documents at interception, coupled with an ownership claim and supporting material produced only after issuance of a show-cause notice, failed to discharge that burden where the alleged owner had not claimed the goods during investigation. Absolute confiscation was therefore sustained. Carriers transporting foreign-origin gold without lawful documents remained liable to penalty. Penalty against the person alleged to have arranged the transaction was justified for misleading the investigation, but its quantum was reduced.

Personal penalties for alleged aiding and abetting of gold smuggling under Section 112(a) require proof beyond suspicion. Statements recorded under Section 108 may be substantive material, but accomplice statements require corroboration in material particulars under Section 114 illustration (b) of the Indian Evidence Act. Co-accused statements, call-data material and alleged use of a syndicate member's SIM card did not establish complicity where no incriminating material or SIM card was recovered and the SIM usage remained unverified. Calls reporting concealed gold supported the official's explanation. The alleged involvement in smuggling was therefore not proved, rendering the personal penalties unsustainable.

Customs classification of mixed lots of polyester knitted fabric must be determined by the actual composition of each imported consignment. Reclassification from the accepted tariff entry requires cogent technical evidence, such as laboratory testing, establishing that the alternative entry applies; a later change of view or a general description of assorted fabrics is insufficient. In the absence of such evidence, the accepted classification and related concessional-duty treatment continue. Where the dispute is interpretational and no deliberate suppression, wilful misstatement, or intent to evade duty is established, penalty for misdeclaration is not attracted.

Prospective operation of an amendment prevents its use against imports covered by bills of lading issued before the amendment commenced, unless retrospective effect is expressly provided. An amendment effective from 15 June 2026 therefore cannot be invoked to refuse consideration of provisional release under the Customs Act for such imports. Provisional release must be considered under the applicable law and granted on compliance with imposed conditions.

Provisional release of imported goods may be secured without requiring a bank guarantee approaching twice the duty liability where Revenue's interests are adequately protected through proportionate safeguards. Payment of duty on the declared value, coupled with a personal bond for any additional duty ultimately determined, provides sufficient protection pending adjudication. The bank-guarantee requirement was set aside, and release was directed subject to payment of applicable declared-value duty and execution of a personal bond for any balance duty.

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.