Service tax paid under reverse charge on exempt goods transport agency services, despite no tax liability, is treated as a revenue deposit made under a mistake of law rather than duty. The amount falls outside the statutory duty-refund mechanism and must be refunded; retaining it lacks constitutional authority. As the payment is a deposit, the statutory interest regime for duty refunds does not apply. Compensatory interest at 12% per annum is payable from each deposit date until refund.

Provisional attachment, seizure, retention and freezing measures must rest on the material, reasons to believe, complaint and application that originally grounded them. Later FIRs, an ECIR addendum or a subsequent prosecution complaint cannot retrospectively validate measures founded solely on an original FIR; they require an independent statutory basis. Quashing the original FIR does not itself eliminate every predicate offence where subsequent FIRs disclose such offences. Yet those FIRs cannot support confirmation of challenged measures unless they formed part of the original statutory foundation.

Under the PMLA provisional-attachment regime, a developer relying on a joint development agreement must establish enforceable title and payment of consideration for the landowner's share before seeking release or substitution of attached land. Absence of a registered sale deed, proof of payment, or crystallised rights through legal proceedings left the developer with only an uncrystallised contractual interest. Transfers to plot purchasers and insufficient details of unsold plots further prevented proof of a subsisting proprietary share. The attachment therefore remained unaffected.

Under the PMLA, allegations involving IPC and Explosive Substances Act offences included in the Schedule can support money-laundering proceedings even where associated mining-law violations are not scheduled offences. Property may be attached as value equivalent to proceeds of crime regardless of its independent source or pre-predicate acquisition, while the affected person bears the burden to substantiate licit sources. Fair market value at acquisition or possession is the statutory valuation measure; use of guideline or current values does not necessarily defeat attachment where alleged proceeds are independently quantified. Reasons to believe require prima facie material linking assets to proceeds and a risk of alienation, not conclusive proof.

Section 16(1)(b) of the Companies Act, 2013 requires a holistic assessment of whether a company name is identical with or too nearly resembles a registered trade mark. The inquiry is broader than a trade-mark infringement dispute and does not require proof of likely deception or confusion. Rival expressions should not be artificially divided into components merely because they share a common element. TOPLAD and TOPLAND are structurally and phonetically similar when considered as whole names, and omission of the letter "N" does not create sufficient visual or phonetic distinction in ordinary Indian-market pronunciation. TOPLAD therefore too nearly resembles TOPLAND, supporting rectification of the company name.

Optical transceivers that convert optical and electrical signals and operate as hot-pluggable interface components are distinguishable from complete Optical Transport Network products. They do not perform system-level functions such as framing, multiplexing, forward error correction, or operations, administration and maintenance functions. Their functional character therefore supports classification as other telecommunications goods under Customs Tariff Item 8517 7090, rather than under the entry applicable to complete Optical Transport Network products.

DHA algae oil containing DHA alongside palmitic acid and other saturated and unsaturated fatty acids is classified as edible vegetable oil under CTH 15159090. Under Rule 1 of the General Rules for Interpretation, classification follows the heading terms and Chapter Notes; a mixed fatty-acid oil is not a separate chemically defined compound under CTH 2916 merely because DHA is a constituent. Food-industry use does not alter classification. CTH 2106 is likewise inapplicable. Consequently, exemption under Notification No. 50/2017-CUS is unavailable, with differential duty, interest, redemption fine, penalties, and bank-guarantee appropriation sustained.

Transaction value under customs law cannot be rejected solely on NIDB data without cogent proof that the invoice price is inaccurate or that the data concerns comparable goods. Accordingly, enhanced valuation, differential duty for earlier cleared consignments, and confiscation founded on that enhancement do not survive. Duty remains payable on admitted undeclared quantities at the declared unit value. Power-of-attorney holders who exercised effective control over a proprietary concern and its imports fall within the extended concept of importer and remain liable for import obligations arising during the proprietor's lifetime. A substantial quantity discrepancy supports penalty for false declaration, while other penalty directions fail.

Burden of proof for notified gold initially rests on the person in possession under the Customs Act. A delivery challan produced at interception can discharge that initial burden, requiring Revenue to establish foreign origin and smuggling. Seizure from a town location, high gold purity, and absence of evidence of foreign origin or smuggling did not support confiscation. A GST-paid procurement invoice and matching GSTR-2A records supported licit procurement. Without reasonable belief supporting seizure, the gold was not liable to confiscation.

Private Indian-registered vehicles carrying only passenger luggage fall within the private-conveyance regime under Section 43(1), which does not require commercial cargo reporting or a Section 51 export-clearance order. Placement of such a vehicle in a maritime container for safe transit does not convert it into commercial export cargo. Accordingly, re-import duty exemption cannot be refused merely because no Section 51 clearance was obtained on departure. Where electronic Bill of Entry filing requires an IEC or GSTIN that a personal vehicle owner cannot possess, the statutory alternative permitting filing in another manner applies. Customs must accept manual filing and release the vehicle on the required bond.

The provisos to section 56(2)(vii)(b) permit use of the stamp-duty value on an earlier agreement date only where that agreement fixes consideration for the same immovable property ultimately transferred and consideration, wholly or partly, is paid through a non-cash mode on or before that date. A booking agreement for a different old-building flat, with separate consideration, did not establish either requirement for the redeveloped flat registered later. As no prior agreement fixed the registered consideration for the transferred property, and no legally established payment linkage was shown, the concessional valuation date was unavailable. The addition for excess stamp-duty value over registered consideration was sustained.

Section 250(6) requires appellate orders to identify issues, decisions and reasons. Sending hearing notices to an email address other than the one supplied in the appeal form, coupled with an ex parte assessment, justified restoration for fresh adjudication after an effective hearing. Under section 272A(1)(d), non-compliance with a notice under section 143(2) and the first notice under section 142(1) constituted separate defaults. Successive section 142(1) notices concerning similar issues constituted one continuing default rather than separate penal defaults. Penalty liability was accordingly confined to the two distinct defaults, and penalties for the remaining successive notices were deleted.

Interest on refinanced borrowings qualifies for deduction under Section 24(b) where the original borrowing funded construction of let-out house property and a direct, verified nexus between the original loan and refinancing is established. Consistent treatment in earlier assessments supports the claim unless the use or nature of funds has changed. Section 14A disallowance cannot apply where no exempt income was earned, notwithstanding investments capable of generating such income. Interest attributable to borrowings used for investment may be capitalised if the actual deployment of funds and related interest allocation are verified.

Jurisdiction to impose penalties under Section 271D rests with the competent prescribed authority. The Standard Operating Procedure operationalising Penalty Units for Chapter XXI penalties ended the transitional arrangement under the Faceless Penalty Scheme, 2021, which had allowed an Assessment Unit to act as a Penalty Unit. Once Penalty Units became operational, an Assessment Unit could no longer issue a penalty order under Section 271D. A penalty imposed thereafter by an Assessment Unit was without jurisdiction and liable to be quashed.

Penalty notices under sections 271(1)(c) and 271AAB(1A) must identify the exact charge or statutory clause invoked. Retaining both concealment and inaccurate-particulars limbs without selecting one renders initiation defective; similarly, failing to specify the relevant 271AAB(1A) clause is invalid because the clauses impose distinct conditions and penalty rates. Alleged cheque-paid salary returned in cash supports only a limited bogus-salary disallowance. The penalties fail for want of definite notice, while the expense disallowance remains limited.

Unexplained-money additions based on seized loose sheets require evidence establishing the assessee's ownership of, or nexus with, the recorded cash entries. Entries lacking the assessee's handwriting, signature, identifiable contributors, independent verification, or other corroboration cannot alone support the addition, particularly where the preparer's statements are contradictory and undisclosed. Election-related receipts and payments recorded in May 2019 fall in financial year 2019-20 and, if taxable, relate to Assessment Year 2020-21 rather than Assessment Year 2019-20. The addition was therefore deleted for the year under consideration.

Reassessment jurisdiction under Sections 147(1) and 148 requires the Assessing Officer to form a bona fide belief, based on relevant tangible material, that income chargeable to tax has escaped assessment. Recorded reasons stating only that claims required verification or that supporting particulars were unavailable establish, at most, a reason to suspect. Where available financial statements were not scrutinised and no belief of income escapement was recorded, the statutory jurisdictional conditions were not met; the Section 148 notice and consequential reassessment were without jurisdiction and quashed.

Section 69 applies to investments not recorded in the taxpayer's books and does not permit aggregate bank credits to be treated automatically as unexplained investments without identifying an unrecorded asset or investment. Where date-wise cash transactions are furnished, withdrawals are followed by deposits, and debit entries substantially correspond with credits, the bank-account pattern may show circulation of funds rather than undisclosed investment. On those facts, the addition based on aggregate cash deposits and other bank credits was deleted, with only a nominal closing balance remaining unexplained.

Profits from disclosed BSE futures and options transactions cannot be treated as unexplained cash credits where financial statements record them as operational revenue and contract notes, tax records, bank statements, annual accounts, transaction statements and confirmations establish their genuineness. The absence of evidence that brokers or counterparties were tainted, or that profit-making trades were pre-arranged, distinguishes such transactions from artificial loss arrangements involving reversal trades. On the preponderance of probabilities, the transactions were genuine; therefore, the cash-credit addition and the consequential alleged commission-expenditure addition were deleted.

Taxability of salary from foreign employment depends on the individual's non-resident status and whether the income accrued in India. Employment records showing work for a foreign entity abroad, together with passport entries and NRE account records evidencing USD receipt, are relevant to those questions. The absence of foreign tax returns, a tax residency certificate, or proof of foreign tax payment alone does not establish that the salary accrued in India or justify Indian taxation.