Competing interests in land within a larger survey-number area require clear identification of the respective plots and shares before any potential sale of attached property. Revenue authorities are to assist with demarcation, supported by plans and revenue records submitted by the claimants. Lifting the attachment remains contingent on establishing valid salable title and verifying the claimant demands. Proceedings arising from the FIR remain stayed pending further consideration of these property claims.

Form I for a Bill of Entry for Home Consumption requires importers to declare goods, tariff classification, assessable value, duty components, exemptions, invoice particulars, transport details, and supporting documents for customs assessment. Importers must confirm the accuracy of invoices and related records, disclose valuation-affecting restrictions, post-import price adjustments, additional payments, royalties, related-party relationships, and relevant Special Valuation Branch status. Preferential rate of duty claims require trade-agreement, certificate-of-origin, originating-criteria, accumulation, back-to-back certification, and transport details, together with an importer certification that goods qualify as originating goods.

Form III prescribes a boat-note for transhipment, reshipment and same-bottom cargo. It records issue, boat, tindel, vessel, cargo-report and transhipment particulars; package details; and same-bottom goods discharged overside or on the wharf. Cargo movement, receipt on board, and commencement and completion times require signatures of the proper officer and ship's officer, as applicable. The form is issued in duplicate with prescribed physical specifications.

Import cargo boat note in Form II records goods delivered to a cargo boat, barge or lighter for landing from a specified vessel. It captures the boat note and import particulars, vessel, berth and landing-place details, package quantity, description, marks, numbers and consignors' names. Signatures of the proper officer, ship's officer, shipper's representative and agent are required, with subsequent certification of landing or receipt by the mukadam and proper officer. The form is pink and issued in duplicate.

Boat Note for export cargo records delivery of goods to a cargo boat, barge or lighter for shipment on a specified vessel. It includes issue details, export and shipping bill particulars, vessel and berth information, package quantity, goods description, marks, consignee names, and signatures of the proper officer, ship's officer, shipper's representative and agent. Separate entries confirm shipment and receipt on board and record loading times. The form has prescribed green colour, dimensions, margins, perforation and column widths.

Substance over form governed the treatment of housing-scheme collections where powers of attorney, control over funds and construction operations showed that the assessee conducted the building business for personal benefit. The intermediary construction firm could therefore be disregarded as a profit-diversion device, collections were treated as trading receipts, and profit was estimated after rejection of inadequately maintained books. Cash payments to the controlled firm were treated as loans or debts rather than payments to an independent entity; other cash payments required reconsideration under the Rule 6DD(j) exception and applicable circular. Loans were assessed as undisclosed income because the contemporaneous search statement was accepted over a later unsupported explanation.

AssetPlus has launched Portfolio Management Services for certified Mutual Fund Distributor partners to digitally onboard, track, manage and report PMS investments for eligible high-net-worth clients. PMS distribution requires NISM Series-XXI-A certification and operates within the APRN distributor-registration framework. PMS comprises individually managed portfolios run by SEBI-registered Portfolio Managers and held in clients' demat accounts. The minimum investment is Rs. 50 lakh, and offerings are governed by the SEBI (Portfolio Managers) Regulations, 2020. The platform provides daily reconciliation of holdings, performance and valuations.

Post-supply discounts issued through tax credit notes may be excluded from taxable value only if the recipient reverses input tax credit attributable to the discount. Pending portal-based verification, suppliers may obtain a Chartered Accountant or Cost Accountant certificate detailing the credit notes, linked invoices, reversal amounts, and supporting reversal records. For discounts within the prescribed annual tax threshold, a recipient undertaking or certificate may be used instead. Such evidence is admissible in scrutiny, audit, investigation, and other proceedings, including for past periods.

Customs declaration of private property held by aircraft captains and crew requires flight details, crew identification, and particulars of currency, travellers' cheques, tobacco, alcohol, watches, jewellery and other articles. It also covers aircraft imprest cash, cash collection, and gold, coin and bullion. Articles intended to be landed must be separately identified. The captain must certify the declaration's truth and sign it, subject to prescribed maximum dimensions.

Cargo Manifest Form III requires air cargo details identifying the owner or operator, aircraft registration, flight particulars, loading and unloading points, air waybill number, number of packages, and nature of goods. It includes separate fields for owner or operator and official use, requires preparer and page information, and prescribes a maximum overall form size.

Passenger Manifest requirements require aircraft owners or operators to report flight, passenger, journey, and travel-document particulars. Passenger reporting includes identity, transit or disembarkation status, nationality, residence address, and birth details; journey reporting includes origin, destination, and passenger name record locator. Additional fields cover Indian address and residence-country details, crew documentation, foreign-passenger visa information, and EDIFACT and carrier contact particulars. Fields marked with an asterisk are non-mandatory, and the manifest requires preparation and pagination particulars.

Customs Form No. I under regulation 3(1) requires a General Declaration containing aircraft, flight routing, crew, passenger and cargo particulars. It distinguishes embarking, disembarking and through passengers and requires identification of origin, en route and destination places. Health information must cover illnesses, disease-spread conditions, and disinsecting or sanitary treatment. The authorised agent or pilot-in-command must certify that all particulars, including those in supplementary forms, are complete, exact and true to the best of their knowledge.

Section 138B of the Customs Act permits reliance on inquiry statements in adjudication only when the statutory circumstances for non-production of the maker are established or the maker is examined before the adjudicating authority. If the statement is admitted in the interests of justice, the affected party must have an opportunity to cross-examine. Mere asserted non-cooperation by an employee does not establish unavailability, incapacity, adverse-party interference, or impracticability of production. Statements proposed for revocation of a customs broker's licence therefore require examination of their makers and cross-examination where admitted in evidence.

Reassessment after processing under section 143(1) remains permissible where tangible material gives the Assessing Officer reason to believe that income escaped assessment, because such processing involves no scrutiny assessment or prior opinion. Information on cash deposits preceding unsecured loans provided a sufficient basis for reopening; conclusive proof of escapement was unnecessary at the notice stage. Cash-credit additions require examination of identity, creditworthiness and transaction genuineness, and were restored for fresh adjudication with a reasonable opportunity to produce evidence. The long-term capital-gain addition and denial of exemption remained sustained because the records did not substantiate the claimed valuation.

Territorial jurisdiction of an ITAT bench to entertain an appeal is determined by the situs of the jurisdictional Assessing Officer under standing orders issued under Rule 4(1). Where the jurisdictional Assessing Officer is located at Mangaluru, outside the territorial allocation of the Panaji Bench, the appeal lies before the Bengaluru Bench. Appeals instituted before the Panaji Bench in those circumstances are not maintainable and must be filed before the competent Tribunal bench.

Contractual under-loading charges arising from idle freight under a fuel supply agreement are deductible business expenditure where the agreement places liability on the seller and recovery occurs through sale-bill adjustments. As commercial obligations incurred in ordinary coal-supply operations, they are not expenditure for an offence or conduct prohibited by law under Explanation 1 to section 37(1). Demurrage for delayed loading or unloading at railway sidings is compensatory for extended use, storage and custody facilities and incidental to goods transportation. It likewise remains deductible where it is not a fine or statutory penalty. This treatment sustains deletion of disallowances for both categories of expenditure.

Remuneration received by a working partner is generally taxable as business income. However, the proviso to Section 28(v) excludes salary or remuneration, including any part of it, that has not been allowed as a deduction to the firm under Section 40(b). Accordingly, remuneration disallowed to the firm is not chargeable in the partner's hands. This exclusion applies to both salary and remuneration and prevents taxation of amounts for which the firm received no corresponding deduction.

Section 68 addition for an unsecured loan or advance is unsustainable where the taxpayer establishes the creditor's identity, creditworthiness and transaction genuineness through PAN, tax return, financial statements, bank records, ledger entries and company master data. Sufficient reserves and surplus support the creditor's capacity, while receipt and repayment through banking channels with matching accounting entries support genuineness. A prior statement by an alleged entry operator does not, without evidence of control over the creditor during the relevant year or linkage to the transaction, establish that the loan was an accommodation entry. The taxpayer consequently discharges the burden of proof under Section 68.

Interest expenditure cannot be allocated to or capitalised in capital work-in-progress when available interest-free funds exceed the value of that work-in-progress and are sufficient to finance it entirely. In the absence of a demonstrated nexus between borrowed funds and the capital asset, related interest disallowance is unsustainable. The interest expenditure therefore remains outside the cost of capital work-in-progress.

Cash deposits sourced from a nephew's agricultural-land sale proceeds and existing cash in hand are not unexplained where sale deeds substantiate the sale and receipt of consideration. The family relationship, sale transaction and receipt of cash support the stated source when they remain undisputed. A minor difference between sale consideration and the deposited amount, or the seller's ability to maintain a separate bank account, does not by itself displace that explanation. The deposits are therefore satisfactorily explained, and no addition for unexplained money under Sections 68 or 69A is warranted.