Section 110(5) of the Customs Act limits freezing of a bank account to an initial six months, extendable by a further six months only on recorded reasons. Once the maximum twelve-month period expires, continued freezing is impermissible. Issuance of a show-cause notice under Section 124 does not independently authorise continuation of the freezing beyond that statutory period. The bank account must therefore be de-frozen after expiry of the maximum permissible period.

Customs duty exemption disputes fall outside High Court appellate jurisdiction under Sections 130 and 130E where they intrinsically concern the rate of duty or valuation for assessment. The jurisdictional exclusion has broad scope and covers entitlement to exemption for stores imported for salvage operations, because such questions are connected with duty assessment and may have wider fiscal ramifications. Challenges to Tribunal orders on those issues lie exclusively before the Supreme Court under Section 130E, rather than the High Court.

Statutory appellate remedy for a customs provisional-release order may displace writ intervention, even where the petitioner alleges that relied-upon reports were not supplied. The customs authority must supply those reports, while any request for testing by an independent agency may be considered by the appropriate authority. The resulting test report should be circulated before a final decision. The appellate process is to be considered expeditiously, rather than remanding the provisional-release matter in writ jurisdiction.

Section 28(9A)(b) treats a pending proceeding and operative interim protection that prevent customs determination as an enumerated circumstance, causing the Section 28(9) period to run from cessation of that circumstance. A Call Book transfer is consequential only, and an administrative circular cannot override this statutory timing rule. Where noticees request deferment pending related proceedings, know why determination is postponed, and fail to report cessation, communication requirements may be substantially fulfilled. Availability of an effective statutory appeal and the bar on approbation and reprobation weigh against discretionary writ relief; substantive duty-demand issues remain available in the appellate process.

Appellate Authority must decide the customs dispute independently on its own merits and without being influenced by prior judicial observations. The impugned order remained undisturbed, while the special leave petition was disposed of subject to that clarification. Pending interlocutory applications were also disposed of. This preserves an uninfluenced merits determination at the appellate stage despite non-interference with the impugned order.

Internal TNMM for IT services requires separate benchmarking of AE and non-AE segments where their functions and risks differ. Certified segmental results included in transfer-pricing records can support the analysis; audited segmental accounts are not required. An AE captive-service margin within the arm's-length range supports acceptance of the AE segment. Ind AS 32 presentation of CCDs as equity does not change their underlying debt character. Interest remains deductible while CCDs are outstanding, subject to confirmation that no actual conversion or redemption occurred during the relevant year.

Penalty for under-reporting of income was not leviable where the income returned in response to a reassessment notice was accepted without any addition. The penalty order failed to identify how the accepted returned income constituted under-reporting. Consistent treatment was required because penalty had been dropped on identical facts for an earlier assessment year. The circumstances also fell within the exclusion for a bona fide explanation accompanied by full disclosure of material facts. The penalty was therefore directed to be deleted.

Capital gains from independently registered sale deeds accrue in the respective assessment years of transfer, rather than collectively in one year. Reassessment may be sustained where returns were only processed under section 143(1) and subsequent scrutiny information indicates transfers in other years. Stamp-duty valuation, indexed cost and proportionate capital-gains computation require fresh factual examination. Deduction claims for eligible reinvestment may be considered in appellate proceedings despite no revised return. Tax relief is required to prevent the same capital gains being taxed twice across assessment years. Concealment penalties do not apply where transactions were disclosed, the year of taxability was debatable, and additions partly arose from deeming valuation.

Reassessment jurisdiction under Section 147 requires a correct factual foundation and genuine application of mind to material available to the Assessing Officer. Treating an assessee as a non-filer despite a return having been filed under Section 139(1) makes the satisfaction underlying the notice under Section 148A(b), the order under Section 148A(d), and the reassessment factually erroneous. Reliance solely on portal information without verifying the return record renders the assumption of jurisdiction unsustainable. The reassessment proceedings and consequential reassessment order were therefore invalid and set aside.

Capital-asset classification of the land and the alternative reinvestment-exemption claim require complete supporting material, including the sale agreement, diversion orders, sale documents and reinvestment evidence. Where that material was absent before the Assessing Officer and appellate forums, income cannot be properly computed or the claims determined on merits. Assessment under Sections 144 read with 147 therefore requires fresh adjudication by the original authority through a speaking order after examination of complete evidence.

Partial income-tax refunds comprising refundable tax and accrued interest under Section 244A must be appropriated first towards the interest component and then towards principal tax. Section 244A treats the refund due as including both tax and interest and aims to compensate the assessee for the Revenue's retention of refundable money. Adjusting a partial payment first against tax would stop further interest accruing on the unpaid interest balance, giving the Revenue an unjust advantage. Interest-first appropriation preserves full compensation for the time value of money and promotes equitable tax administration.

Interest paid or credited to bodies constituted under Central, State or Provincial legislation qualifies for the notified tax-deduction exemption because statutory creation, rather than mere incorporation or regulation under general law, is decisive. The exemption also applies independently to companies whose entire share capital is Government-held. Interest earned on Government scheme funds held by companies solely as nodal or implementing agencies is not their income where beneficial ownership remains with Government; no tax-deduction obligation arises. Payments to temples require recipient-wise verification of declarations, tax returns, condonation materials and other evidence before relief from default can be determined under the first proviso to section 201(1).

Section 80G regular-approval applications should not be rejected solely for delayed filing of Form No. 10AB where the institution held provisional approval and no deliberate suppression, contumacious conduct, or unintended benefit is indicated. Substantive eligibility must instead be examined. A public charitable trust remains irrevocable by operation of law unless its governing instrument expressly reserves revocation, re-transfer of income or assets, or re-assumption of control. Therefore, the absence of express irrevocability or dissolution clauses, and a corresponding affirmative Form No. 10AB response, do not independently justify rejection. The application requires fresh consideration of charitable objects, genuineness of activities, statutory compliance, and an effective hearing opportunity.

Capital gains arise where a registered sale deed effects transfer and records consideration, unless cogent evidence displaces the recorded transaction or its taxability. Unsupported assertions of coercion or non-receipt of consideration do not negate transfer. Section 292BA cures omission of the Document Identification Number from an assessment order where a valid number is otherwise generated and communicated. Section 292BB deems service of a notice where the taxpayer participates without timely objection. An additional ground requiring fresh factual investigation is not admissible merely as a legal issue. Although the assessment and chargeability remain sustainable, long-term capital gains require recomputation after verification of the cost of acquisition and related components.

Incorrect PAN allotment due to an entity-status error does not justify penalties where the company complies under a subsequently allotted PAN reflecting its correct legal status. Non-compliance penalties require absence of reasonable cause; receipts recorded under the incorrect PAN were accounted for and offered to tax under the correct PAN, avoiding separate assessment and double taxation. Deletion of quantum additions removes the basis for concealment or inaccurate-particulars penalties. Where audited books, the tax audit report and the income-tax return are furnished under the correct PAN, duplicate compliance is not required merely because an erroneous PAN exists. Non-filing under the incorrect PAN is treated as a technical default in these circumstances.

Working-capital adjustments in transfer-pricing benchmarking may be required where differences in inventory, trade receivables and trade payables materially affect operating margins and can be eliminated through a reasonably accurate computation. Relief depends on verification of reliable supporting data and the adjustment calculation. An alternative charitable deduction claim for a CSR contribution may be considered at the appellate stage where it arises from facts already on record, even if omitted from the income-tax return. Disallowance of the payment as business expenditure does not independently prevent charitable-deduction eligibility, which remains subject to verification of the donee, receipt, payment mode and statutory limits.

Specific investigation information identifying an alleged accommodation-entry loan and establishing a live nexus with escaped income supports reassessment at the stage of recording reasons, where only a prima facie belief is required. Loan confirmations and banking-channel transactions alone do not establish the creditor's identity, creditworthiness and the transaction's genuineness when the creditor does not respond to statutory notices or examination and adverse investigation material remains unrebutted. The primary burden for an unexplained cash credit consequently remains undischarged, and related interest may be disallowed. Current-year and brought-forward business losses require supporting material showing compliance with conditions for determination and carry-forward.

Penalty for misreporting under section 270A cannot be imposed where penalty proceedings and the statutory notice identify only under-reporting. Under-reporting attracts penalty at 50% of tax payable, while misreporting attracts 200% and requires one of the specified circumstances under section 270A(9). These are distinct defaults with separate ingredients, defences and consequences for immunity. Where neither the assessment order nor the notice alleges misreporting or identifies a relevant statutory circumstance, a later penalty on that aggravated charge lacks prior notice and is unsustainable. The penalty was deleted.

Documentary proof including the lender's PAN, loan confirmation and bank statement established receipt of a family loan through banking channels; absent identified defects, the unexplained-investment addition was deleted. The stamp-duty-value addition requires fresh examination because the MOU, payment, possession, part performance, property condition, valuation and the alleged purchase of two apartments were not properly assessed. Applicability of the deemed-property-value provision, the statutory definition of transfer and part-performance principles must be independently evaluated after an effective hearing, without mere reliance on the remand report.

Transactional Net Margin Method applies to bundled intra-group management and IT services where receipt, commercial benefit and non-duplication are established; a joint-venture partner's approval of another amount does not justify using the Comparable Uncontrolled Price Method, and the related transfer-pricing adjustments were deleted. Arm's length interest on external commercial borrowings requires fresh determination under the statutory transfer-pricing framework. Site-restoration costs incurred to meet a contractual restoration obligation remain deductible as revenue expenditure despite being debited against an existing decommissioning provision. Interest for advance-tax default is not chargeable to the extent tax deducted at source by the resident payer covers the taxpayer's total liability.