Regulation 17(1) requires a customs broker revocation notice within 90 days of the licensing authority receiving an offence report. Where no separate investigation report exists, Customs Act show-cause notices and their relied-upon documents constitute that report if they contain the investigation summary and prima facie allegations. The licensing authority cannot defer the mandatory period by later seeking documents already annexed to the notices. A notice issued after the prescribed period leaves no statutory authority to revoke the licence; revocation must be set aside and the licence restored.

Provisional release of detained imported goods under section 110A of the Customs Act, 1962 may be granted pending adjudication where adequate safeguards protect recovery of differential duty. Payment of duty on the declared value, a bank guarantee for 30% of the differential duty, and a personal bond for the remaining 70% sufficiently secure revenue interests. Continued detention is unwarranted once these conditions are met, and the goods are to be released provisionally subject to compliance.

Conditional registration under Section 12AB and approval under Section 80G cannot make their applicability or consequential tax benefits contingent on future litigation. The statutory framework permits the Commissioner to grant or reject registration and approval in accordance with law, but does not confer power to impose conditions dependent on a future judicial outcome. Quasi-judicial powers must arise expressly from statute. Once granted, registration and approval operate according to law; any cancellation or withdrawal must follow the prescribed statutory mechanism. Conditions imposing such contingencies were beyond statutory jurisdiction and must be deleted.

Complete books of account, bills, vouchers, ledgers and stock registers that are produced, accepted and free from identified defects cannot be disregarded merely because the net-profit rate has declined. Increased consumption of goods, raw materials and components, together with higher employee costs, can explain a lower net-profit ratio. In the absence of rejection of the books, a marginal net-profit variation alone does not justify an addition; the addition based solely on that variation was deleted.

For unquoted equity shares, Section 56(2)(viib) taxes issue consideration exceeding fair market value, while Rule 11UA(2) permits valuation under the Net Asset Value or Discounted Cash Flow method. The Assessing Officer may scrutinise the valuation report, underlying data, assumptions and methodology, but cannot replace the selected prescribed method merely because projections, management estimates or standard disclaimers appear unsatisfactory. Rejection requires identified defects in the data, assumptions or methodology. Where both prescribed valuations supported the issue price and no specific defect was established, the Section 56(2)(viib) addition was deleted.

Post-2021 search-related reassessment requires information in the nature of incriminating material found during the search. Where reassessment was initiated on issues arising from seized material and returned income was accepted after verification, transport expenses unsupported by incriminating material could not be examined or disallowed through revisionary jurisdiction. The reassessment was therefore neither erroneous nor prejudicial to the interests of the Revenue, rendering the revision invalid.

Reassessment requires recorded reasons demonstrating independent application of mind and a rational, live nexus between identified material and income alleged to have escaped assessment; generic accommodation-entry information cannot replace that jurisdictional foundation. An enquiry initiated for alleged bogus purchases cannot support treatment of the same transactions as unexplained loans, because those characterisations require materially different factual and evidentiary enquiries. For loan credits, confirmations, bank statements, tax returns, ledgers and affidavits may discharge the initial burden on identity, source and banking trail. An immediate credit in a lender's account alone does not establish an accommodation entry without transaction-specific contrary material.

Alleged bogus purchases linked to accepted sales do not warrant disallowance of the full purchase value where books of account, stock records and quantitative particulars remain unrejected, payments are made through banking channels, and no material disproves the sales. Where accommodation bills may have been used but goods could have been procured from alternative sources, only the embedded profit element is taxable under unexplained expenditure provisions. Consistent profit estimation in earlier assessment years supports applying a 3% rate, confining the addition to 3% of the alleged purchases.

Market data charges as royalty under the India-USA DTAA - Seconded-employee cost reimbursements as fees for included services under the India-US DTAA Market data charges as royalty under the India-USA DTAA - Taxability of market data charges recovered from Indian associated enterprises as royalty under the India-USA DTAA - HELD THAT: - The factual position was indistinguishable from that in the assessee's earlier cases for AY 2017-18 [2023 (5) TMI 544 - ITAT MUMBAI] wherein such receipts ... ... ...

Cash deposits from recorded cash sales during demonetization - Rental receipts reflected in Form 26AS - Disallowance of business expenditure for non-deduction of tax at source - Premature challenge to initiation of penalty proceedings - Enhancement for alleged unexplained receipts in a running account - Cessation of liability on reversal of overdraft interest Unexplained cash deposits from recorded cash sales during demonetization - Addition of cash deposited in specified bank notes during de... ... ...

Unexplained cash credit in share capital and share premium - Non-appearance of subscriber-directors in response to summons - Addition of share capital and share premium as unexplained cash credit where documentary evidence regarding the subscribers was furnished but their directors did not appear in response to summons - HELD THAT: - The Tribunal found that the assessee had produced PAN details, addresses, audited financial statements, bank statements, MCA data and confirmations from the share s... ... ...

Taxability of compensation for compulsory acquisition of rural agricultural land - Exemption under the RFCTLARR Act - HELD THAT: - The land was undisputedly rural agricultural land and was therefore not a capital asset. Applying Circular No. 36/2016, the Tribunal held that compensation received on compulsory acquisition under the RFCTLARR Act is exempt from income-tax. [Paras 5, 6] The addition made by treating the compensation as short-term capital gain was directed to be deleted. Final C... ... ...

Cash-credit addition for share capital and premium - Independent inquiry in revisionary set-aside proceedings - there was non- appearance of the directors in response to summons u/s 131 Addition of share capital and share premium as unexplained cash credit where the inquiry directed in revisionary proceedings was not undertaken and the assessee-company's directors did not comply with summons - HELD THAT: - The original reassessment had examined the share issue, while the assessee and the ... ... ...

TP Adjustment - Arm's length price of operational expense reimbursements - Deductibility of unutilised foreign tax credit - Tax deduction at source on non-resident service payments Arm's length price of operational expense reimbursements - Arm's length price adjustment for reimbursement of operational expenses incurred by foreign associated enterprises for the assessee's NVOCC operations - HELD THAT: - The material supporting virtually the entire reimbursement transaction had ... ... ...

Employee long-term reward insurance premium as business expenditure - Reassessment on subsequent scrutiny information - change of opinion - Proof of statutory approval for reassessment notice Reassessment on subsequent scrutiny information - change of opinion - Validity of reassessment for disallowance of employee long-term reward insurance premium, where the claim had been allowed in an earlier assessment year - HELD THAT: - Acceptance of the claim in A.Y. 2012-13 did not preclude reassessme... ... ...

Deduction under section 80P(2)(a)(i) - Interest on deposits with co-operative banks - HELD THAT: - Interest earned by such a society on funds deposited with a co-operative bank or bank retains its character as income attributable to its business of providing credit facilities to members and is eligible for deduction. As the facts were identical to those in the precedents considered, the disallowance was unsustainable. See KARNATAKA STATE CO-OPERATIVE APEX BANK [2001 (8) TMI 9 - SUPREME COURT]... ... ...

Corporate guarantee as international transaction - Arm's length pricing of corporate guarantee - Deduction for Special Economic Zone development profits Corporate guarantee as international transaction - Transfer-pricing adjustment on corporate guarantee issued for the borrowing of an associated enterprise - HELD THAT: - The Explanation to section 92B includes guarantee within capital financing. The corporate guarantee increased the associated enterprise's creditworthiness and involve... ... ...

Ad hoc disallowance of business expenditure - Specified Bank Notes deposits from recorded cash sales - Unsecured loan credits - creditworthiness and genuineness Ad hoc disallowance of business expenditure - Ad hoc disallowance of employee benefit and other business expenses by applying an average expense-to-turnover ratio without identified defects in the accounts - HELD THAT: - Neither the AO nor the appellate authority identified any particular expenditure as bogus, non-genuine, excessive o... ... ...

Enhanced penalty for misreporting of income u/s 270A(8) - Requirement of a specific statutory charge for misreporting - Substitution of penalty charge in appellate proceedings Misreporting of income - Specific statutory charge - Enhanced penalty - Sustainability of enhanced penalty for misreporting in respect of omitted salary, interest and rental receipts without identifying and establishing an applicable circumstance under section 270A(9) - HELD THAT: - Under-reporting and under-reporting i... ... ...

Income deemed to accrue or arise in India - Telecommunication-service receipts - royalty/FTS or business profits - India-UK DTAA. HELD THAT: - The controversy was found to be recurring, with coordinate Bench decisions in the assessee's own cases consistently [2019 (11) TMI 1110 - ITAT MUMBAI] AND [2023 (4) TMI 1478 - ITAT MUMBAI] resolving it in favour of the assessee. As the Revenue could not distinguish those decisions on facts or law, the Tribunal followed them. Those decisions proceed... ... ...