Tariff classification of imported sensors turns on their objective characteristics and functions under General Rules for Interpretation Rules 1 and 6, with specific entries prevailing over residuary Heading 9031 and Revenue bearing the burden of disproving the declared classification. Thermistor-based temperature sensors, electrochemical gas-analysis sensors, pedal-position assemblies, vehicle-specific retainers and magnetic-field speed sensors require classification according to their respective functions. Section 28 cannot solely alter classification after a completed nil-duty assessment without proposed duty recovery. Alternative FTA relief requires proof of notification conditions and origin documents; revenue neutrality cannot rest on hypothetical exemptions. Wrong self-assessment alone does not establish suppression for extended limitation, and IGST interest requires a substantive statutory charging or borrowing provision.

Penalty under Sections 114(i) and 117 of the Customs Act, 1962 requires more than deficient verification of an exporter's antecedents or KYC particulars. Section 114(i) requires an identifiable act, omission or abetment with a statutory nexus to goods becoming liable to confiscation. Where a Customs Broker obtained authorisation, verified the exporter's IEC through DGFT and ICEGATE, and reviewed an earlier shipping bill, absent evidence of involvement in substitution, stuffing, transport, tampering, false documentation, collusion, container control or facilitation of prohibited exports, a KYC lapse remains regulatory. Section 117 cannot independently impose a residuary penalty without an established statutory contravention.

Limitation for a departmental Customs Act appeal is determined by its original filing date; call-book placement and later renumbering do not create a fresh appeal. SAD refund under Notification No. 102/2007-Cus. requires payment at import, subsequent sale, VAT/CST payment, and supporting records. Verified Bills of Entry, sales invoices, reconciliation, and reliable Chartered Accountant certification can establish correlation despite generic goods descriptions or differing grade nomenclature. Consignment-agent sales do not defeat refund where authority to sell and tax-payment correlation are certified. On these requirements, refund remains admissible and recovery based solely on denial cannot continue.

Show-cause notice limits adjudication to the material factual and legal grounds alleged; liability cannot rest on unalleged consignor or exporter status, missing consignor authorisation, or knowing participation in an attempted export. Courier KYC verification under Regulation 13(i) requires reliable, independent and authentic material, not necessarily two identity documents where one genuine driving licence proves identity and address. Regulation 13(j) concerns unauthorised outsourcing of regulatory functions, not physical consignment collection. Penal liability for concealed prohibited goods requires cogent proof that the authorised courier knowingly participated in, facilitated, or made a false declaration; reliance on consignor-provided information alone does not establish knowledge or intent.

Extended-period customs notices require specific allegations of collusion, wilful misstatement or suppression; later assertions outside the notice cannot supply those statutory preconditions. Where differential duty and interest have been paid pursuant to an audit demand, accepted, and the audit objections closed, a subsequent notice is not authorised after payment and intimation and cannot be sustained through the extended limitation provision without pleaded foundational facts. The alternative appellate remedy does not bar writ jurisdiction where later duty proceedings are ex facie without jurisdiction or barred by limitation.

Prospective operation of an import-notification amendment prevents its application to a provisional-release request where the Bill of Lading predates the amendment and the amendment contains no express retrospective effect. Customs authorities must consider provisional release under the Customs Act and may release the goods subject to lawful conditions; they cannot reject or decline consideration solely by relying on the later amendment. The applicable rate of duty remains subject to determination in adjudication under the statutory rules governing the relevant date for duty assessment.

An amendment to an exemption notification applies prospectively unless it expressly provides otherwise and cannot govern imports covered by bills of lading issued before its effective date. Refusal to consider provisional release on the basis of such a later amendment is therefore unwarranted. Requests for provisional release of the goods must be considered under Section 110A of the Customs Act, 1962, consistently with the earlier common order on similar goods, and release must follow once lawfully imposed conditions are met.

Prospective operation of exemption-notification amendments prevents customs authorities from applying an amendment that commenced after the relevant bills of lading to deny consideration of provisional release. Without express retrospective effect, the amendment does not govern the imports. Requests for release must therefore be considered under Section 110A of the Customs Act, 1962, on lawful conditions; goods must be released provisionally upon compliance, without affecting independent adjudication proceedings.

Imported areca nuts detained on suspicion of misdeclaration must undergo the prescribed food-import clearance procedure under Regulation 5. The process is initiated through the Integrated Declaration Form and processed through the Food Import Clearance System. Representative samples must be sent to the jurisdictional food safety authority to examine whether the goods are roasted areca nuts, their moisture content, nature and composition, and fitness for human consumption. Customs may separately forward samples to SIIB and take further action in accordance with law on the resulting material.

Endorsement and delivery of order bills of lading to purported importers transfer title, leaving the exporter without a subsisting claim to re-shipment or sale proceeds absent a lawful basis. Imports routed to non-existent entities without mandatory importer-exporter codes, with documents transferred outside normal banking channels, constitute illegal imports; the goods are prohibited and liable to confiscation under the Customs Act, 1962. Concurrent factual findings of a systematic fraudulent import arrangement support confiscation and penalty and ordinarily raise no substantial question of law.

A jurisdictional High Court judgment remains binding on authorities within its territorial jurisdiction unless stayed, modified, or reversed by a competent court. Registration under section 12AB and approval under section 80G granted to comply with such a judgment cannot be qualified by caveats based solely on a proposed appeal or Supreme Court challenge. Conditional recognition was not authorised by the statutory scheme and conflicted with the High Court's directions. The caveats subjecting registration, approval and consequential benefits to the proposed challenge's outcome were unsustainable and required deletion.

Third-party search material relating to a non-searched person must be assessed through section 153C; using it in a regular section 143(3) assessment creates a jurisdictional defect. No section 14A read with Rule 8D expenditure disallowance arises without exempt income, and such disallowance cannot form a book-profit adjustment. Foreign-exchange losses on revenue liabilities and business-linked forward contracts are revenue expenditure, while capital-account losses require capitalisation. Third-party Excel-sheet information cannot alone support a capital-gains addition where underlying material is undisclosed and cross-examination is denied; the seizure presumption does not extend to another person.

Unverifiable purchases arising from missing supplier confirmations, complete addresses and PAN details can justify rejection of books of account under Section 145(3), notwithstanding production of ledgers and a GST-based reconciliation of purchase and creditor balances. Profit estimation following book rejection must nevertheless remain reasonable and be supported by comparable industry data. Where the declared gross profit rate is materially below comparable rates, gross profit may be estimated at a fair rate rather than an excessive rate; the addition is consequently recomputed using a 4% gross profit rate on declared turnover.

Transactional Net Margin Method (TNMM) was identified as the most appropriate method for benchmarking an export transaction with an associated enterprise because it had been consistently accepted for the same transaction in earlier assessment years. No change in facts or law justified departure from that approach, and prior application of TNMM had resulted in no transfer-pricing adjustment. Consequently, a transfer-pricing adjustment determined under the Comparable Uncontrolled Price method could not be sustained.

Reassessment notices for assessment years commencing on or before 1 April 2021 remain subject to the limitation available under the pre-amendment regime under the first proviso to Section 149(1). For Assessment Year 2015-16, that preserved period expired on 31 March 2022, making a notice issued on 7 April 2022 time-barred; subsequent provisos cannot enlarge the preserved restriction. Sufficient cause for delayed appeals may arise where proceedings were initially filed before an incorrect territorial forum, communications were not received at an old address, and prompt action followed knowledge of the assessment.

Stay of recovery of disputed income-tax demand was extended where delay in disposal of the appeal was not attributable to the assessee, the relevant assessment year was covered by a pending Advance Pricing Agreement, and the assessee had furnished the required bank guarantee under the earlier stay condition. The continuing prima facie case, balance of convenience and relative hardship supported protection from recovery. The stay operates for 180 days or until disposal of the appeal or the assessee's acceptance of the Advance Pricing Agreement, whichever occurs first.

Recovery of outstanding tax demand pending appeal may be stayed where the taxpayer establishes a prima facie case and balance of convenience. Consistent use of the Transactional Net Margin Method in earlier accepted years, followed by a Comparable Uncontrolled Price Method adjustment without a demonstrated change in facts, supported interim protection. Applying the payment requirement under the second proviso to section 254 of the Income-tax Act, recovery was stayed upon payment of 20% of the outstanding demand. The remaining demand was stayed for 180 days or until disposal of the appeal, whichever occurred earlier.

Section 69 links an alleged unexplained investment to the financial year in which the investment is actually made, rather than the year in which title is perfected by registration. Bank-channel payments made in November 2017 fell in FY 2017-18; subsequent registration in FY 2018-19 did not shift the investment to that later year because Section 69 contains no deeming fiction to do so. Consequently, an addition for AY 2019-20 based on those payments was unsustainable and deleted.

Export incentives directly linked to export activity form part of the tested party's operating results under the Transactional Net Margin Method. They must therefore be included as operating income when computing the tested party's profit level indicator and arm's length margin. Excluding them solely because selected comparables do not receive similar incentives would distort the tested party's operating margin, particularly where incentives received by comparables are treated as operating income. The recomputation consequently includes export incentives in the tested party's operating income.

Rectification jurisdiction cannot be used to reconsider the factual basis of an earlier order. A miscellaneous application relying on dates relating to the proposal, approval and transmission of a transfer-pricing reference, rather than the date previously recorded as received by the Transfer Pricing Officer, sought review of the finding that the assessment was time-barred. Such reconsideration exceeds rectification jurisdiction; the miscellaneous application was therefore treated as an impermissible review and dismissed as devoid of merit.