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.

Cancellation of charitable registration under Section 12AB(4) requires cogent material proving a specified violation, namely non-genuine activities or departure from charitable objects. Assessment-related verification issues, procedural deficiencies, unregistered lease documentation, incidental receipts, unsupported expenditure, family management without prohibited benefit, and recorded donations do not alone meet that threshold. Educational surplus does not negate charitable status where education remains the predominant object and surplus is retained and applied for infrastructure and charitable purposes. Cancellation was therefore invalid and registration was restored. As rejection of Form No. 10AB rested solely on cancellation, that rejection could not survive and appropriate registration was required to be granted.

Healthcare services delivered through mobile medical units under a government tender constitute medical relief and charitable purpose where the objects are exclusively healthcare-focused and bar commercial operations. Contractual receipts, tax withholding and surplus do not negate charitable status absent independent profit-making, profit distribution, departure from charitable objects or impermissible application of income. Documentary support for medical activities and reasonable remuneration to specified persons do not establish non-genuineness merely because of a related-party relationship. Regular registration should not be refused on those grounds. Cancellation of provisional registration requires a separate notice identifying statutory grounds and an effective opportunity to respond; without those safeguards, cancellation is unsustainable.

Investor compensation limited to shortfalls after realisation of a defaulting member's assets, while preserving recovery rights and excluding brokers, does not confer a prohibited benefit on the Stock Exchange or its members; trust exemption therefore remains available. A notified Investor Protection Fund may retain exemption for eligible contributions, while specifically directed corpus donations are exempt capital receipts; the restriction on simultaneous exemption claims applies prospectively from assessment year 2025-26. An irrevocable trust deed barring reversion of funds and directing residual assets to SEBI on dissolution satisfies irrevocability requirements. Interest on separately held auction proceeds is not taxable where held in a fiduciary capacity without beneficial ownership under the real-income principle.

For a search initiated after 1 April 2021, Explanation 2 to section 148 deems the Assessing Officer to have information suggesting income escapement for the three immediately preceding assessment years. Where an assessment year falls within that period, jurisdiction must be assumed through reassessment proceedings under sections 147 and 148. An assessment under section 143(3), without issuing a section 148 notice, lacks jurisdiction and is liable to be quashed.

Cash payment for immovable property was satisfactorily explained by accumulated foreign salary earnings of the taxpayer and spouse for purposes of Section 69A. Foreign employment, substantial cash earnings, accepted remittances, travel history, and the absence of evidence of undisclosed income-generating activity in India established a credible and financially sufficient source. Missing customs declarations, currency-encashment records, or a precise historical cash trail did not negate the demonstrated underlying source merely because each accumulated savings tranche could not be traced exactly. The payment was therefore not assessable as unexplained money.

The first proviso to section 149(1) retains the pre-amendment limitation period for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, the six-year limitation under the unamended provision expired on 31 March 2022. Notices issued from 1 April 2021 for that year were outside the period protected by TOLA. Directions creating a legal fiction for reassessment notices could not extend an already expired statutory limitation where TOLA was inapplicable. Consequently, a section 148 notice issued on 31 July 2022 was time-barred, invalidating the consequential reassessment proceedings and order.