Revenue must maintain consistent positions where materially identical service-tax disputes involve the same show-cause notice basis, demand period, computation and Tribunal reasoning. Challenging a Tribunal ruling for one assessee after accepting the identical ruling for a similarly situated assessee is inconsistent with fairness and equality in revenue administration. Extended limitation for a service-tax demand requires specific allegations and proof of fraud, collusion, wilful misstatement or suppression of facts, coupled with intent to evade duty. Without proof of that prescribed conduct, the extended period is unavailable and a delayed demand is time-barred.

Section 5(1)(b) permits provisional attachment only where there is a reasonable apprehension that the person concerned may deal with or alienate property to frustrate confiscation. A pre-existing interim judicial restraint against creating third-party rights, together with admitted insolvency proceedings concerning the secured debt, restricted dealings in the mortgaged property. These circumstances removed any credible risk of alienation or transfer capable of frustrating confiscation, rendering the statutory condition for provisional attachment unmet and the attachment and its confirmation unsustainable.

Provisional attachment under the Prevention of Money Laundering Act requires material establishing a likelihood that proceeds of crime will be concealed, transferred or otherwise dealt with to frustrate confiscation. Mortgages created in favour of secured creditors before attachment, coupled with an existing restraint on third-party rights and no auction, execution, attachment or sale process, did not establish that risk. Pending insolvency proceedings served to ensure an orderly resolution of competing rights. Accordingly, the statutory condition for confirming the provisional attachment was not met, and the properties remained subject to the final outcome of the insolvency proceedings.

The first proviso to Section 45(1) of the Prevention of Money Laundering Act exempts every woman accused from the statutory twin conditions for bail, without classification by education, status, or profession. The exemption is discretionary and does not create an automatic right to bail. Regular bail remains subject to ordinary considerations, including the prima facie case, gravity of allegations, attributed role, flight risk, and potential interference with witnesses or evidence. The dispensation is linked to substantive equality and the constitutional protection for women under Article 15(3). Prolonged custody, lack of need for further interrogation, delayed trial, and absence of tangible interference risks may support exercise of the discretion.

Section 94 permits a personal guarantor in default to initiate a personal insolvency resolution process and propose a repayment plan, while Section 96 grants an interim moratorium. These provisions require a genuine effort to resolve insolvency and cannot be used to obstruct a financial creditor's lawful security enforcement. Withdrawal of an earlier application after enjoying the interim moratorium, followed by a fresh application immediately after issuance of a possession notice, without any intervening repayment effort, demonstrated an intent to stall recovery proceedings. The personal guarantor's application was therefore rejected as an abuse of the insolvency process and interim moratorium.

Section 12A of the Insolvency and Bankruptcy Code, read with Regulation 30A, ordinarily requires an initiating applicant to seek CIRP withdrawal in Form FA, with prescribed creditor approval and security for CIRP costs. Where creditor claims have been settled or agreed to be settled, but CIRP costs remain uncrystallised and the required bank guarantee cannot be furnished, those formalities may create a procedural stalemate. In exceptional circumstances, continuation of CIRP may be unwarranted where no resolution plan is available and the Resolution Professional's entitlement to CIRP costs remains protected through pending adjudication and a binding undertaking to pay the determined costs.

Section 164 of the Companies Act, 2013 prescribes disqualifications for appointment or reappointment as a director but does not authorise deactivation of a Director Identification Number (DIN). DIN deactivation is governed by Rule 11 of the Companies (Appointment of Directors) Rules, 2014, requiring compliance with that rule. Recording a DIN as disqualified under Section 164(2)(b) without establishing Rule 11 compliance or giving the affected director an opportunity of hearing breaches principles of natural justice. An uncommunicated and unpublished internal assertion of disqualification cannot support a contrary website status. The website notice showing the DIN as disqualified was therefore quashed.

Section 149 of the Customs Act must be read harmoniously with the India-Japan CEPA origin rules when an importer seeks preferential duty after clearance. Appendix-A to Annexure-2 permits an importer lacking a Certificate of Origin at importation to seek refund of excess duty by later producing a certificate issued under the prescribed procedure. A valid retrospectively issued Certificate of Origin supports amendment and reassessment of Bills of Entry for preferential tariff treatment under Notification No. 34/2018-Customs. The certificate must therefore be considered by the adjudicating authority in reassessing the duty claim.

Mono Ethylene Glycol Reclamation Plant imported for offshore and onshore petroleum operations qualified for customs exemption under Serial No. 404 read with Serial No. 4 of List 33 of Notification No. 50/2017-Customs during the pre-amendment period. Eligibility required the goods to fall within the tariff coverage in the main notification and meet prescribed conditions; List 33's reference to tariff heading 8430 did not independently restrict the wider description of specialised petroleum-service equipment. End-use certification supported this interpretation. A later specific entry for the plant operated prospectively and did not displace coverage under the existing general entry. The ambiguity rule favouring Revenue did not apply because the exemption provision was unambiguous.

Immunity from penalty under Section 270AA is not defeated solely by delayed furnishing of Form No. 68 where the taxpayer has paid the assessed tax and interest and has not appealed the quantum assessment. Filing the prescribed form late is a technical and venial procedural lapse when payment substantially within the relevant period demonstrates an intention to seek immunity. The assessing authority must identify any unfulfilled statutory condition before denying the claim. The immunity application requires reconsideration after giving the taxpayer an opportunity of hearing.

Section 292BC treats approvals in assessment proceedings as administrative and supervisory, preventing invalidation for defects in reasons, form, authentication or communication; absence of DIN and clerical inaccuracies therefore did not invalidate section 153D approval. Excess cash found beyond recorded balances was assessable as unexplained money under section 69A despite an erroneous reference to section 69, because the correction neither changed the income source nor caused prejudice requiring a further hearing. The claimed personal-cash explanation lacked a reliable contemporaneous trail. Stock-shortage addition requires fresh factual examination where work-in-process and normal manufacturing loss are supported by quantitative reconciliation and records.

Extended assessment jurisdiction under the fourth proviso to Section 153A requires material showing that escaped income is represented by an identifiable asset specified in Explanation 2, together with the Assessing Officer's objective and independent recorded satisfaction. Loose papers alleging cash payments for land, without identifying or establishing acquisition of immovable property or another specified asset, do not satisfy these conditions. Material potentially supporting an unexplained-investment addition cannot replace the separate jurisdictional basis for extending the search-assessment period. Subsequent merits enquiries cannot cure an invalid notice; notices and consequential assessments issued without the required foundation are without jurisdiction.

Reassessment based solely on information that immovable property was sold lacks a jurisdictional foundation unless material links the sale proceeds to income escaping assessment. Statutory approval must reflect the approving authority's independent and reasoned satisfaction; mechanical endorsement is insufficient, rendering the reassessment and resulting assessment invalid. Agricultural land located beyond the prescribed municipal limits falls outside the definition of a capital asset where supported by relevant municipal evidence and affidavit. Its transfer therefore does not attract capital-gains taxation, and any related long-term capital-gains addition is unsustainable.

Section 149(1)(a) imposes a three-year limitation for reassessment notices. The extended period under section 149(1)(b) applies only where material indicates escaped income of at least Rs. 50 lakh represented by an asset, expenditure, or book entry, and its conditions require strict satisfaction. Jurisdiction under section 148A(d) must be founded on the issue that remains after considering the taxpayer's response. Where the surviving basis is denial of a deduction below the statutory threshold, rather than an allegation of unexplained deposits, the extended limitation is unavailable. A notice issued beyond three years is therefore time-barred, and the consequential reassessment lacks jurisdiction.

For AY 2016-17, section 80AC did not apply to deductions under section 80P, as its expanded scope applied only from AY 2018-19. Section 80A(5) required a deduction claim in a return of income but did not require filing within the section 139(1) due date. A return accepted under section 148 and used for assessment satisfied that requirement; the sixth proviso to section 139(1) did not apply to a co-operative society or section 80P deduction. Interest from temporary bank deposits of idle business funds of a co-operative credit society was attributable to its member-credit business and qualified under section 80P(2)(a)(i), where the funds were not liabilities payable to members.

Prior opportunity before an adjustment in return processing is a mandatory statutory condition; failure to provide it vitiates the processing and renders the adjustment unsustainable. A charitable entity's accumulation claim requires substantive examination in rectification proceedings where revised Form 10B, an asserted inadvertent return-filing error, and supporting indemnity material are produced. The corrected claim should not be rejected merely because it requires reasoning; the taxable-income computation must be reconsidered and consequential rectification undertaken in accordance with law.

Commissioner (Appeals) must decide income-tax appeals on merits through a written, reasoned order identifying the points for determination and the basis of the decision. Sections 250 and 251 permit ex parte disposal where an assessee does not participate despite notice, but do not permit dismissal solely for non-prosecution. Such dismissals require fresh adjudication after a reasonable opportunity of hearing. Delay caused by electronic communication of an appellate order, despite a request for physical service, warrants a liberal, justice-oriented approach to condonation where the delay is not inordinate.

A consequential assessment framed under Section 143(3) read with Section 263 lacks an independent legal basis when the revisional order under Section 263 that authorised it has been quashed for a jurisdictional defect and the original assessment stands restored. In those circumstances, the consequential assessment cannot survive, and the disallowance is deleted. The characterisation of the claimed loss as capital or revenue expenditure does not require consideration because the assessment fails for want of a valid jurisdictional foundation.

Reassessment proceedings require communication of the recorded reasons to the assessee and valid service of the mandatory notice under section 143(2). Where the assessee requests the reasons after responding to the reassessment notice, dispatch alone is insufficient if the reasons and notice are returned unserved. Available addresses in departmental records, including prior use of affixture, must be considered for effective service. Failure to furnish the recorded reasons and serve notice under section 143(2) renders a reassessment under sections 144 and 147 invalid and void from inception.

Concealment penalty cannot be sustained under Section 271(1)(c) when the quantum addition forming its sole basis has been deleted. Where a challenge to the quantum deletion remains pending, the underlying issue is debatable; penalty for concealment is not leviable on such a debatable issue. The concealment penalty was therefore deleted in favour of the assessee.