Foreign-origin black pepper and socks not notified as goods under Section 123 of the Customs Act, 1962 do not trigger a reversed burden of proof. Revenue must establish smuggling through adequate evidence before confiscation or penalties can be sustained. Failure to discharge that burden means the goods are not liable to confiscation and penalties cannot be imposed.

Gold bracelets recovered during frisking at a domestic airport, outside a customs area, require a reasonable belief supported by circumstances that they are smuggled before seizure under the Customs Act, 1962. Recovery at the domestic airport, recorded purity of the bracelets, and the absence of an investigation establishing smuggling do not support that belief. Section 110 therefore does not apply on these facts; the bracelets are not liable to confiscation and no penalty is imposable.

Customs exemption for electronic paver finishers depends on the goods' capability and characteristics in their imported condition. A machine capable of paving only up to the prescribed width through optional external bolt-on extensions does not satisfy an exemption condition requiring that capability, particularly where the extensions were neither supplied nor declared. Non-disclosure of the machine's actual paving capability and the need for external additions constitutes misdeclaration of material particulars, supporting extended-period duty recovery. Personal penalty requires proof of a director's specific act or omission causing the misdeclaration; without individual culpability, such penalty is unsustainable.

Preferential-duty exemption based on a certificate of origin cannot be denied unless reliable, certificate-specific retroactive verification establishes that the certificate is invalid or non-genuine. Verification relating to a different certificate or another importer cannot be applied mechanically to separately issued certificates. Where imported goods are unavailable for confiscation and were not released against a bond or undertaking, redemption fine in lieu of confiscation is not imposable. These principles preserve the preferential tariff claim and negate consequential differential duty, interest, penalty and confiscatory liability.

Penalty for improper importation under Section 112(a) requires an act or omission that renders goods liable to confiscation under Section 111. Where goods are unavailable for confiscation and no redemption fine is imposed, and the related duty demand and importer penalties based on the same reclassification have been set aside, penal liability of a director lacks a legal basis. The director's penalty is therefore unsustainable.

EPCG exemption under Notification No. 16/2015-Customs remains available despite non-registration of the authorisation at the original import port, non-production for debit at clearance, and absence of the prescribed undertaking where capital goods were initially imported under the export-oriented unit scheme and later debonded. Furnishing the EPCG authorisation and required particulars to jurisdictional authorities, obtaining exit and no-dues permissions, undertaking the export obligation, and providing an undertaking for future duty shortfall substantially satisfy the notification's conditions. Such defects constitute procedural lapses rather than substantive non-compliance warranting denial of exemption.

EPCG export-obligation enforcement cannot be initiated before expiry of the authorisation's prescribed fulfilment period. Where a six-year period is fixed, alleged non-fulfilment cannot trigger enforcement under the applicable customs exemption framework before that period ends, rendering such proceedings premature. Revenue-neutrality observations concerning IGST payment and corresponding input tax credit do not conclusively establish entitlement where they remain subject to verification. Revenue may examine the underlying data and determine the IGST credit issue in fresh proceedings lawfully initiated after expiry of the export-obligation period.

Customs broker licences already revoked under a valid earlier order cannot be revoked again through separate proceedings for another alleged violation. Where multiple grounds for revocation exist, they should be addressed in the same revocation proceedings. A subsequent order purporting to revoke an already revoked licence lacks statutory authority and creates unnecessary multiplicity of litigation, placing the second revocation outside the statutory framework.

MEIS benefits for notified exports were not defeated by failure to mark "Y" in the rewards column against every item in electronic shipping bills. A declared intention to claim rewards, genuine exports, and no customs objection supported treating the omission as a condonable procedural lapse. Marking "Y" for the first item in each shipping bill made the physical-examination objection immaterial, preserving substantive entitlement under the beneficial scheme.

Interest on duty payable upon redemption of confiscated imported goods arises only after the consequent duty liability is assessed and determined through the Section 28 mechanism. Section 125(2) makes duty and charges payable when the redemption option is exercised and accepted; the original Bill of Entry assessment, based on the declared goods description, does not determine liability arising from later confiscation, reclassification, redemption fine and penalty proceedings. Interest cannot run for the period before the adjudication-based determination, but remains payable thereafter where applicable, subject to reassessment and credits for payments or appropriations.

Section 24 of the Prohibition of Benami Property Transactions Act, 1988 permits provisional attachment after a show-cause notice where the Initiating Officer has reason to believe property is benami, apprehends its alienation, and obtains prior approval. It prescribes no mandatory interval between notice, approval and attachment; same-day action is therefore not inherently mechanical. Cross-examination in summary proceedings is not automatic and requires a request demonstrating necessity. Benami status may be inferred cumulatively where acquisition funds remain unexplained and financial records, tax returns, inventories and banking transfers do not establish the ostensible owner's independent financial capacity. Such material may support confirmation of attachment where consideration is attributable to the beneficial owner.

Section 69 applies only where an assessee's investment and its source remain unsatisfactorily explained. Additional evidence admitted under Rule 29 established that residential property was jointly acquired and that each co-owner made payments through identifiable banking channels from explained sources. The agreement, developer receipts, co-owners' bank statements, TDS certificate and society share certificate did not establish that the assessee alone funded the entire investment. Accordingly, the investment could not be treated as unexplained in the assessee's hands, and the addition was deleted.

Cash deposits in specified bank notes claimed as festive-season sales may be treated as unexplained credits where sale invoices, item-wise stock records, stock availability and supporting operational evidence do not substantiate the source. Exceptional cash-sale volumes immediately before demonetisation and insufficient staffing or related expenditure may further undermine the sales explanation. Reduction of the gross-profit element from the addition avoids double taxation. The amendment to section 115BBE enhancing tax consequences operates prospectively absent express retrospective effect; it does not apply to Assessment Year 2017-18, for which sustained unexplained-credit additions are taxable at normal rates.

Skill-based online card-game winnings fall within taxable income and remain subject to the special tax treatment for winnings; the online mode and the game's skill-based character do not alter that treatment. Taxability, however, requires identification of real net winnings rather than aggregation of gross credits entering an online gaming wallet. Repeated wallet credits, debits and redeployment do not themselves establish taxable income. The restriction on deducting expenditure does not displace the prior requirement to determine whether an actual gain arose. Verified buy-in amounts must therefore be considered in determining net accretion, and a net loss does not create taxable winnings.

Agricultural-land exclusion from capital-gains taxation requires the taxpayer to establish actual agricultural use through cogent evidence; revenue records, acreage descriptions, or unsupported claims are insufficient. Section 50C permits adoption of the stamp valuation applicable to the same property and transfer where declared consideration is lower. Reference to the Departmental Valuation Officer is not required unless the taxpayer claims before the Assessing Officer that stamp value exceeds fair market value. Stamp-value computation must be confined to the verified extent actually transferred. Natural-justice objections fail where notice, participation, opportunity to respond, and appellate verification are available. A limited-scrutiny jurisdiction objection requires material showing examination of a wholly unconnected issue.

Treaty-based claims for refund of excess dividend distribution tax for foreign shareholders remain subject to the applicable India-Singapore treaty rate and the governing larger-Bench determination. Supporting facts already on record permit adjudication in line with that determination. Market research and media measurement costs are deductible as revenue expenditure under section 37(1) when incurred wholly and exclusively for advertising and media-planning services, evidenced by client agreements and invoices, and connected with revenue generation, business nexus and commercial expediency.

Penalty under Section 271AAA does not arise merely because physical stock of polished diamonds is lower than recorded book stock. Undisclosed income requires search material establishing income not recorded in the books. Where no search-based evidence proves that the stock discrepancy resulted from unrecorded sales or that sale consideration remained unaccounted for, the statutory conditions for penalty are not met. Confirmation of a quantum addition does not independently establish penalty liability, as penalty provisions require strict construction. The penalty was therefore deleted.

Redevelopment compensation paid for hardship and displacement while vacating a residential property is characterised as a non-taxable capital receipt, irrespective of its use for alternate accommodation or any erroneous partial income offer. Taxable salary cannot be determined solely from gross receipts in Form 26AS where employer-issued Form 16 and settlement records identify exempt gratuity and other components, absent contrary component-wise evidence. Deductions for donations and savings-bank interest remain allowable when supported by donation receipts, bank records, proper income disclosure, and compliance with the applicable eligibility and statutory-limit conditions.

Delayed electronic filing of Form 10B under section 12A(1)(b) is a procedural and evidentiary lapse, not a substantive failure, where the audit report was timely obtained, filed before the return deadline, and charitable exemption conditions are otherwise met. Such delay does not by itself defeat exemption under section 11; eligibility remains subject to verification and reconciliation with Form 10AC. The adjustment under section 143(1) did not breach natural justice where the variance schedule identified the delayed filing and the assessee had opportunities to address it during rectification and appellate proceedings.

Equivalent debenture subscriptions by an associated enterprise and an unrelated subscriber under substantially identical contractual terms, including a 15% interest rate, support use of the unrelated-party investment as a reliable internal comparable for arm's-length pricing. In the absence of material distinguishing facts, debt-equity recharacterisation producing a nil arm's-length price is not supported. Interest-limitation disallowance requires recomputation after verification of the correct associated-enterprise interest and EBITDA figures. Set-off of brought-forward business losses depends on verification of the eligible loss quantum, availability, and implementation of relevant appellate directions.