Retail-sale packaging materials and containers classified with a good are disregarded in assessing whether non-originating materials satisfy the applicable process or change-in-tariff-classification requirement, and in determining whether the good is wholly obtained or produced. Their value must, however, be included as originating or non-originating material when calculating qualifying value content.

De minimis origin treatment permits goods failing an applicable change in tariff classification requirement to qualify as originating where non-originating materials remain within prescribed limits. Goods outside Harmonised System Chapters 50 through 63 are subject to a value limit based on FOB value, while goods within those chapters are subject to a total weight or value limit. Non-originating materials must also be included for any qualifying value content calculation. Wholly obtained goods may retain originating status where limited non-originating materials from other chapters are used.

Origin status under the India-New Zealand Free Trade Agreement is not conferred where non-originating materials undergo only insufficient working or processing. Combinations of listed minimal operations remain insufficient to confer originating good status. All operations undertaken within a Party on a given good must be assessed collectively when determining whether the overall working or processing is insufficient.

Material value is determined by CIF value for imported materials; by the price paid or payable, applicable imported-material value, or earliest ascertainable price for materials obtained within a Party; and by all production costs, including reasonably allocable general expenses, for self-produced materials. Transport costs, non-recoverable duties and taxes, and net waste and spoilage costs may be added for originating materials and deducted for non-originating or undetermined-origin materials. No adjustment is permitted where costs are unknown or unsupported.

Qualifying Value Content may be calculated by either a build-down method based on non-originating materials or a build-up method based on originating materials. Under build-down, QVC equals the FOB value less the value of non-originating materials, divided by the FOB value and multiplied by 100. Under build-up, QVC equals the value of originating materials divided by the FOB value and multiplied by 100.

Bilateral cumulation treats an originating good or material from one Party as originating in the other Party when incorporated into production there. The input must qualify as originating under rule 3 and meet all other applicable origin requirements. Qualifying inputs from either Party may therefore contribute to preferential origin for goods produced in the other Party.

Wholly obtained or produced goods qualify as originating in one or both Parties where they consist of specified plants, animals, natural resources, marine products, qualifying waste and scrap, or goods derived solely from those materials. Marine products qualify where taken by Party-flagged vessels or processed on qualifying factory ships, while seabed goods require relevant exploitation rights under international law.

Originating goods under the India-New Zealand free trade arrangement qualify if wholly obtained or produced in either or both Parties' territories under the specified criteria. Alternatively, goods may qualify by satisfying the applicable Product Specific Rules in Annexure A and all other prescribed requirements.

Valuation and content calculations distinguish CIF value-the price paid or payable at importation including the good's cost, insurance and freight-from FOB value, being the price paid or payable when loaded for export, including costs to place it on the carrier. QVC denotes qualifying value content expressed as a percentage. The value of originating and non-originating materials covers such materials used in production in one or both Parties, with the latter expressly including undetermined-origin materials. All costs and values must be recorded and maintained under the Generally Accepted Accounting Principles applicable where the good is produced.

The Customs Tariff (Determination of Origin of Goods under the Free Trade Agreement between India and New Zealand) Rules, 2026 govern origin determination for goods under that agreement. Made under the Customs Tariff Act, 1975, the Rules enter into force on 20 October 2026.

Jurisdiction over a tenant's injunction suit concerning alleged tenancy rights in car-parking spaces is determined from the plaint averments, assumed to be true. Where the plaint alleges tenancy, payment of rent, and interference with possession, the dispute falls within the expression "relating to recovery of possession" under the Presidency Small Cause Courts Act. Its overriding clause prevails over the stated exclusion, while the government-premises exception does not apply without proof that the premises are governed by the relevant eviction law. Composite tenancy may also attract rent-control jurisdiction. The public-premises law does not bar injunction relief where it provides no tenant remedy. Exclusive jurisdiction therefore lies with the Small Causes Court, not the City Civil Court.

Treaty benefits for an item of income may be refused under the principal purpose test where, on all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction that directly or indirectly produced it. A benefit remains available if granting it accords with the object and purpose of the relevant treaty provisions.

The Director (Excise and Taxation), previously appointed under the Punjab Value Added Tax Act, 2005, is appointed as Additional Commissioner of State Tax under the Punjab Goods and Services Tax Act, 2017 with immediate effect. The appointment is made by the Governor of Punjab under section 3 of the Punjab Goods and Services Tax Act, 2017.

Penalty for abetment of improper import of concealed gold requires proof that the person knowingly received, assisted, or otherwise abetted the offending goods. Telephone-call evidence, without reliable corroboration, does not by itself establish knowing receipt or abetment. A third-party statement cannot be relied on when its maker is not made available for cross-examination. The absence of an inculpatory statement by the alleged recipient, incriminating material from the appellant's premises, and admitted knowledge of the goods left the statutory ingredients of abetment unproved; the penalty was unsustainable.

Unexplained expenditure may be added only where it remains unsupported or unexplained on the material on record. Credit-card expenditure was accepted as duly explained in the remand report; therefore, no addition could be sustained for alleged unexplained investment or expenditure. The addition was deleted.

Section 54 deduction applied to capital gains from transfer of a long-term asset comprising a residential house or land appurtenant to it. A structure constructed shortly before the transfer did not preclude relief where its existence was on record and its residential character had not been specifically rejected. Treatment of the asset as an open plot was therefore insufficient to deny the deduction, and the disallowance was deleted.

Unabated assessments under section 153A require incriminating material found during the assessee's own search; third-party material must be addressed through section 153C after prescribed satisfaction. Prior approval under section 153D requires independent, year-specific and assessee-specific consideration of the material and draft assessment orders, rather than a combined mechanical approval. Assessments based on third-party seized material cannot be framed under section 153A or section 144 without following section 153C, including application of its relevant block-period rules. Where an assessment lacks these statutory foundations, penalties arising solely from it do not survive.

Section 2(22)(e) treats gratuitous loans or advances to qualifying shareholders, made merely because of their shareholding, as deemed dividend. An advance given where the shareholder provides collateral security and a personal guarantee for the company's borrowings, thereby conferring a commercial benefit, falls outside that provision. A short-term advance repaid during the year and used to acquire shares in a group concern to facilitate business expansion is commercial rather than gratuitous and is not taxable as deemed dividend.

Additions for estimated profit on alleged unaccounted purchases and for unexplained closing stock require independent evidentiary support beyond a survey notebook recording purchase offers. Where accepted offers are entered in regular books, recorded purchases are corroborated by broker affidavits, and no further material establishes undisclosed transactions or stock, an inference of unaccounted purchases or closing stock lacks an evidentiary basis. Both additions were therefore unsustainable.

Revisionary jurisdiction over a capital-gains assessment cannot be invoked merely because the Commissioner prefers further or different verification. Where computation, sale and purchase materials, and agricultural-land investment were furnished and examined in assessment, the Assessing Officer's partial disallowance of exemption and acceptance of the remaining computation constituted a fact-based plausible view. Non-application of stamp-duty valuation provisions did not itself establish an error unsustainable in law and prejudicial to Revenue. The revisionary order was unsustainable, and the original assessment stood restored.