Issues: Whether an addition arising from the difference between foreign contribution reported under the FCRA and voluntary foreign contribution reported in the income-tax return could be made through an adjustment under section 143(1).

Analysis: The FCRA disclosure included interest earned from investment of foreign contribution, whereas the income-tax return separately reported voluntary foreign contribution and interest income. The respective disclosures served different statutory purposes and required appreciation on the basis of substance over form. The records showed that the relevant foreign contribution and interest income had been declared, the accounts were audited without qualification, and the same reporting methodology had been accepted in other years. A mismatch requiring reconciliation and explanation could not be treated as undisclosed income without properly considering the material and explanation furnished in the rectification proceedings.

Conclusion: The section 143(1) addition was unsustainable and is deleted, in favour of the assessee.

Issues: Whether the branch-office expenses claimed against interest on income-tax refund were allowable as business expenditure after transfer of the branch undertaking.

Analysis: Sections 28(i) and 29 of the Income-tax Act, 1961 govern computation of income and business expenditure. Although the undertaking had been transferred on a going-concern basis, substantial statutory assets were retained. The purpose of retaining those assets, and whether the predominant legal and professional expenses related to continuing business purposes, pending branch-office litigation, or otherwise, was not established on the record. The scope of expenditure incurred for the purpose of business extends beyond immediate profit earning and may include acts incidental to carrying on or preserving a business. The necessary expense-wise factual examination had not been undertaken.

Conclusion: The allowability of the claimed expenses was not adjudicated on merits and requires fresh determination upon de novo assessment.

Issues: (i) Whether addition under Section 56(2)(vii) based on the difference between the stated purchase consideration and stamp-duty value was sustainable; (ii) Whether the assessee had satisfactorily explained the source of investment and stamp-duty payment for purchase of the property.

Issue (i): Whether addition under Section 56(2)(vii) based on the difference between the stated purchase consideration and stamp-duty value was sustainable.

Analysis: The valuation determined by the Departmental Valuation Officer for the entire property was adopted. The difference between the actual consideration and such valuation was below 5%. The valuation mechanism under Section 50C(2) was treated as pari materia with Section 56(2)(vii), making the tolerance available in relation to the valuation difference applicable.

Conclusion: No addition under Section 56(2)(vii) was permissible; the issue was decided in favour of the assessee.

Issue (ii): Whether the assessee had satisfactorily explained the source of investment and stamp-duty payment for purchase of the property.

Analysis: The purchase payments, stamp-duty payment, and tax deducted at source were traceable to the assessee's disclosed bank account and available bank balance. The aggregate investment stood fully explained.

Conclusion: The addition for unexplained investment was unsustainable; the issue was decided in favour of the assessee.

Final Conclusion: Both additions relating to acquisition of the property were deleted.

Ratio Decidendi: Where the departmental valuation produces a variation within the applicable tolerance band, stamp-duty-based addition is unwarranted; an investment evidenced by disclosed bank-account payments is explained.

Issues: Whether surrendered income for Assessment Year 2019-20 was taxable at the enhanced rate under section 115BBE.

Analysis: The enhanced rate introduced through the 2016 amendment operates prospectively from 01.04.2017. Since the assessment year in question was 2019-20, the amended provision was already in force. Charging tax at the normal rate instead of the applicable enhanced rate constituted a mistake apparent from the record capable of rectification.

Conclusion: The surrendered income was liable to tax at the enhanced rate under section 115BBE; the finding is against the assessee.

Issues: Whether exemption under section 10(23C) could be denied solely because the educational institution had not filed its return of income for Assessment Year 2016-17.

Analysis: Section 139(4C)(e) imposed an obligation on specified educational institutions to furnish a return where the prescribed income threshold was exceeded, but, for the relevant year, it did not make filing of the return a condition precedent to exemption under section 10(23C). The Twentieth Proviso to section 10(23C), inserted with effect from 01.04.2023, expressly linked return filing to exemption only for entities falling under sub-clauses (iv), (v), (vi) and (via). The assessee, whether falling under sub-clause (iiia) or (iiiab), was outside that proviso. No finding established failure to satisfy the substantive conditions for exemption.

Conclusion: Exemption under section 10(23C) could not be denied merely for non-filing of the return for Assessment Year 2016-17; the exemption was directed to be granted and the interest-income addition was deleted.

Issues: Whether the notice issued under Section 148 for assessment year 2015-16 on 07.04.2022 was barred by limitation under the first proviso to Section 149(1) of the Income-tax Act, 1961.

Analysis: For assessment years beginning on or before 01.04.2021, the first proviso to Section 149(1) preserves the limitation applicable under the pre-amendment regime. For assessment year 2015-16, the six-year period expired on 31.03.2022. The extended period under the amended provision could not retrospectively revive a time-barred reassessment. The later-inserted provisos concerning exclusion of time were not in force when the notice was issued and, in any event, no additional time had been sought for responding to the notice under Section 148A(b).

Conclusion: The notice under Section 148 issued on 07.04.2022 was barred by limitation; the consequential reassessment order was vitiated and quashed, in favour of the assessee.

Issues: (i) Whether an assessment based on material obtained in a third-party search could validly be completed under section 143(3) instead of section 153C; (ii) Whether disallowance under section 14A read with rule 8D, and the corresponding adjustment to book profit under section 115JB, were sustainable where no exempt income was earned; (iii) Whether foreign-exchange loss arising from restatement of trading liabilities and related forward contracts was allowable as revenue expenditure; (iv) Whether short-term capital gains could be added solely on third-party spreadsheet information without supplying the material or affording cross-examination.

Issue (i): Whether an assessment based on material obtained in a third-party search could validly be completed under section 143(3) instead of section 153C.

Analysis: Sections 153A and 153C prescribe the statutory procedure where seized material from a search relates to a person other than the searched person. The assessment year was an abated assessment because the statutory time for issuing notice under section 143(2) remained available when the search-related information was received. As the assessing authority used information and material obtained from the third-party search to assess the assessee, assessment was required to proceed under section 153C.

Conclusion: The assessment completed under section 143(3) was invalid and liable to be quashed.

Issue (ii): Whether disallowance under section 14A read with rule 8D, and the corresponding adjustment to book profit under section 115JB, were sustainable where no exempt income was earned.

Analysis: No exempt income was earned during the relevant year. The settled rule is that no disallowance under section 14A read with rule 8D can be made in the absence of exempt income. Further, a disallowance computed under section 14A cannot be imported into clause (f) of Explanation 1 to section 115JB for computing book profit.

Conclusion: The section 14A disallowance and the corresponding section 115JB adjustment were deleted, in favour of the assessee.

Issue (iii): Whether foreign-exchange loss arising from restatement of trading liabilities and related forward contracts was allowable as revenue expenditure.

Analysis: The loss arose from exchange fluctuation on supplier liabilities, advances, interest receivables and forward contracts connected with business transactions. Under Accounting Standard-11, exchange differences on settlement or restatement are recognised according to whether they are on revenue or capital account. The identified loss was on revenue account and was not capital or speculative in nature.

Conclusion: The foreign-exchange loss was allowable as revenue expenditure and the disallowance was deleted, in favour of the assessee.

Issue (iv): Whether short-term capital gains could be added solely on third-party spreadsheet information without supplying the material or affording cross-examination.

Analysis: The addition rested solely on an Excel sheet found in a third party's laptop. The underlying material was not furnished to the assessee and no cross-examination of the person from whom it was recovered was permitted. The assessee's sale documents, invoices and payment records supported the disclosed consideration. The statutory presumption concerning seized material did not apply against the assessee in respect of third-party information.

Conclusion: The short-term capital gains addition based on the third-party spreadsheet was unsustainable and was deleted, in favour of the assessee.

Final Conclusion: The assessment founded on third-party search material could not survive outside the section 153C framework, and the challenged disallowances and addition were unsustainable on the applicable substantive and evidentiary principles.

Issues: Whether assessments for years beyond the ordinary six-year block could be initiated under the fourth proviso to Section 153A without establishing that escaped income was represented in the form of a specified identifiable asset and without recording independent jurisdictional satisfaction.

Analysis: The extended period under the fourth proviso to Section 153A is available only upon fulfilment of jurisdictional conditions precedent. Escaped income must be shown from the material available to be represented in the form of an asset specified in Explanation 2, and the Assessing Officer must record objective and independent satisfaction of those conditions. Loose papers recording alleged cash payments towards land, without identification or establishment of an acquired immovable property or other specified asset, do not meet that threshold. Material which may support an unexplained-investment addition under Section 69B cannot itself substitute for the distinct jurisdictional foundation required to invoke the extended search-assessment period. Subsequent merits enquiries cannot cure the absence of jurisdiction when notice was issued.

Conclusion: The extended jurisdiction under the fourth proviso to Section 153A was not validly assumed; the notices and consequential assessments were without jurisdiction and stood quashed in favour of the assessee.

Issues: (i) Whether the continued retention of the seized jewellery, Indian currency, foreign currency and documents complied with the requirements of Sections 17, 20 and 8 of the Prevention of Money Laundering Act, 2002; (ii) Whether retention of jewellery claimed by Petitioners 2 to 5 without independent notice and opportunity of hearing was valid; (iii) Whether the writ petition was barred by the alternative appellate remedy under Section 26 of the Prevention of Money Laundering Act, 2002.

Issue (i): Whether the continued retention of the seized jewellery, Indian currency, foreign currency and documents complied with the requirements of Sections 17, 20 and 8 of the Prevention of Money Laundering Act, 2002.

Analysis: Search, seizure and continued retention under the statutory scheme require recorded reasons to believe founded on material, and the Adjudicating Authority must be satisfied that the property is prima facie involved in money laundering and required for adjudication. The retention order did not disclose meaningful consideration of the partnership records, loan-closure documents, repayment material, jewellery bills, valuation reports, affidavits, income-tax records, travel documents and other evidence produced to establish lawful acquisition. It reproduced allegations founded on suspicion without identifying cogent material linking the seized assets to proceeds of crime. Fresh allegations in the counter affidavit could not cure deficiencies in the recorded order.

Conclusion: The retention order did not satisfy the mandatory requirements for continued retention and was invalid, in favour of the petitioners.

Issue (ii): Whether retention of jewellery claimed by Petitioners 2 to 5 without independent notice and opportunity of hearing was valid.

Analysis: Substantial portions of the seized jewellery were claimed by Petitioners 2 to 5, who were neither accused in the scheduled offences nor independently notified in the retention proceedings. A person whose property rights are directly affected must receive reasonable notice and an opportunity of hearing.

Conclusion: Retention without notice and hearing to the affected claimants violated principles of natural justice, in favour of the petitioners.

Issue (iii): Whether the writ petition was barred by the alternative appellate remedy under Section 26 of the Prevention of Money Laundering Act, 2002.

Analysis: An alternative statutory remedy is not an absolute bar to judicial review where the challenge alleges lack of jurisdiction, breach of mandatory statutory safeguards and violation of natural justice. The challenge to compliance with Sections 17 and 20 and to the absence of the required adjudicatory satisfaction fell within Article 226 jurisdiction.

Conclusion: The availability of an appeal under Section 26 did not bar the writ petition, in favour of the petitioners.

Final Conclusion: Continued retention of property under the Prevention of Money Laundering Act, 2002 requires a reasoned determination based on material connecting the property with proceeds of crime, while preserving notice and hearing safeguards; the investigation against the accused may proceed in accordance with law.

Ratio Decidendi: Statutory powers of search, seizure and continued retention under the Prevention of Money Laundering Act, 2002 cannot rest on suspicion alone and require recorded reasons, cogent supporting material, adjudicatory satisfaction and compliance with natural justice.

Issues: (i) Whether the delay of 596 days in filing the appeal against the revision order was liable to be condoned; (ii) Whether an appeal against the revision order was maintainable where the grounds challenged only the consequential assessment order and disclosed no grievance against the revision order.

Issue (i): Whether the delay of 596 days in filing the appeal against the revision order was liable to be condoned.

Analysis: The statutory discretion to admit a delayed appeal requires establishment of sufficient cause. Pursuit of remedies concerning the consequential assessment, coupled with the assessee's stated acceptance of the revisionary adjustments and failure to challenge them within limitation, did not establish sufficient cause or due diligence for the substantial delay.

Conclusion: The delay was not liable to be condoned; this issue was decided against the assessee.

Issue (ii): Whether an appeal against the revision order was maintainable where the grounds challenged only the consequential assessment order and disclosed no grievance against the revision order.

Analysis: The grounds were directed solely against the consequential assessment and related matters, which were already pursued before the appellate authority. The assessee expressly disclosed that it had raised no ground against the adjustments directed in the revision order, demonstrating absence of grievance against that order.

Conclusion: The appeal against the revision order was not maintainable for want of any grievance against that order; this issue was decided against the assessee.

Final Conclusion: The revisionary order remained unassailed, and the assessee could not use an appeal from that order to challenge the consequential assessment.

Ratio Decidendi: Condonation of delay under the appellate provisions requires a demonstrated sufficient cause marked by bona fides and due diligence; an appeal is not maintainable where the appellant has no grievance against the order appealed from.

Issues: Whether the Official Liquidator should be exempted from filing annual or final accounts for the financial year 2024-25 where audited half-yearly accounts for both halves of that year had been filed.

Analysis: Section 551 of the Companies Act, 1956 requires annual or final accounts. Audited half-yearly accounts for the two respective periods do not replace annual accounts, as consolidation of those accounts is necessary to present the correct financial status of the companies in liquidation.

Conclusion: Exemption from filing annual or final accounts for the financial year 2024-25 was refused.

Issues: (i) Whether the notice for reassessment was issued within the extended limitation period; (ii) Whether participation in reassessment proceedings attracted the deeming provision concerning valid service of notice.

Issue (i): Whether the notice for reassessment was issued within the extended limitation period.

Analysis: For assessment year 2013-14, the original six-year limitation expired on 31.03.2020. The applicable extension carried cases whose original limitation fell between 20.03.2020 and 29.06.2020 only up to 30.06.2020, and the subsequent extension applied to original limitation dates falling between 20.03.2020 and 31.12.2020. The notification extending limitation from 31.03.2021 to 30.04.2021 did not apply, because the original limitation in this case ended on 31.03.2020. The notice, though signed on 31.03.2021, was issued on 01.04.2021.

Conclusion: The reassessment notice was barred by limitation and was invalid, in favour of the assessee.

Issue (ii): Whether participation in reassessment proceedings attracted the deeming provision concerning valid service of notice.

Analysis: The deeming provision addresses objections to service where a person has entered appearance and participated in proceedings despite ineffective service. It does not cure the defect of a notice issued after expiry of the statutory limitation period.

Conclusion: Participation did not preclude the assessee from challenging the notice as time-barred, in favour of the assessee.

Final Conclusion: The consequential assessment orders, being founded on the invalid time-barred notice, were without legal validity.

Ratio Decidendi: An extension of limitation for reassessment notices applies only to cases falling within its expressly specified original limitation period, and a deeming rule regarding service cannot cure a notice issued beyond statutory limitation.

Issues: (i) Whether the challenge to the disclosed parameter-wise technical evaluation was barred by res judicata or constructive res judicata; (ii) Whether the technical-bid evaluation process was arbitrary, opaque and contrary to the requirements of fairness, transparency and equality; (iii) Whether failure to record and communicate reasons for the technical evaluation and disqualification vitiated the process.

Issue (i): Whether the challenge to the disclosed parameter-wise technical evaluation was barred by res judicata or constructive res judicata.

Analysis: The earlier proceedings had not adjudicated the merits of the technical evaluation because the relevant evaluation material had not been disclosed and the challenge was then premature. Liberty had been reserved to pursue remedies following disclosure, and the later communication of parameter-wise marks supplied a fresh cause of action. The legality of that disclosed evaluation could neither have been raised nor decided in the earlier proceedings.

Conclusion: The petitions were maintainable and were not barred by res judicata or constructive res judicata, in favour of the petitioners.

Issue (ii): Whether the technical-bid evaluation process was arbitrary, opaque and contrary to the requirements of fairness, transparency and equality.

Analysis: Judicial review did not entail reassessment of technical merits, but extended to legality of the decision-making process. Comparative criteria required ascertainable standards for identifying the best offer and proportionate scoring, while objective criteria prescribed measurable benchmarks. The evaluation disclosed neither comparative benchmarks nor deficiencies in the proposals. Materially identical proposals and credentials received materially different marks across Missions, including zero marks despite apparent compliance with stipulated benchmarks. Oral presentations could not replace contemporaneous recorded reasons or validate undisclosed standards. The absence of a comparative evaluation summary and meaningful debriefing further undermined transparency. Exclusion of a bidder quoting lower financial bids also implicated public interest.

Conclusion: The technical evaluation process was arbitrary, irrational, non-transparent and violative of Article 14 of the Constitution of India, in favour of the petitioners.

Issue (iii): Whether failure to record and communicate reasons for the technical evaluation and disqualification vitiated the process.

Analysis: Rule 173(iv) and Rule 189 of the General Financial Rules, 2017 required transparency and recording of reasons in evaluation and rejection of technical proposals. The tender terms also required unsuccessful bidders to be informed of reasons for disqualification. Communication of numerical marks without their factual basis, identified deficiencies or comparative rationale did not establish application of mind or permit meaningful scrutiny. The respondents remained bound by their recorded undertaking to furnish reasons; the subsequent direction to provide mark break-ups did not dilute that obligation.

Conclusion: Failure to record and communicate reasons rendered the technical evaluation opaque, arbitrary and contrary to natural justice and fair administrative action, in favour of the petitioners.

Final Conclusion: The impugned technical evaluations and consequential tender awards could not stand; procurement must be undertaken afresh through a lawful, transparent and reasoned process while continuity of public services is maintained.

Ratio Decidendi: In public procurement, technical evaluation must adhere to disclosed and objectively verifiable criteria, and unexplained scoring, undisclosed comparative standards and unrecorded reasons render the decision-making process vulnerable to judicial review under Article 14.

Issues: Whether an otherwise admissible claim for Foreign Tax Credit can be denied solely because Form No. 67 was furnished after the time stipulated under Rule 128(9).

Analysis: The entitlement to Foreign Tax Credit arises substantively under Section 90 and the applicable double-taxation avoidance arrangements, whereas Rule 128 prescribes the procedure and documentation for claiming that credit. Rule 128(9) does not prescribe forfeiture or denial of credit as a consequence of delayed filing of Form No. 67. The subsequent extension of the filing timeline also supports the procedural character of the requirement. Where foreign income has been offered to tax in India, foreign taxes have been paid, and Form No. 67 with supporting evidence has been furnished, a procedural delay cannot defeat the substantive relief or result in double taxation. The administrative condonation mechanism under Section 119(2)(b) does not curtail appellate jurisdiction to grant relief when substantive conditions are met.

Conclusion: Delayed furnishing of Form No. 67 does not by itself disentitle the assessee to Foreign Tax Credit; the claim must be examined on merits after verification of foreign-tax payment and absence of any foreign refund.

Issues: Whether GST registration can be denied on account of a landlord's dispute regarding the applicant's tenancy rights where the applicant prima facie establishes legal possession of the business premises.

Analysis: Registration under Rule 8(1) requires material demonstrating the applicant's legal possession of the premises. The registration authority is not required to adjudicate disputed questions concerning the extent of a lessee's rights or an alleged unauthorised sublease, since such disputes requiring interpretation of lease terms fall for determination before the competent civil or rent-control forum. The lease documents, authorisation by the co-lessees, the managing partner's status as a lessee, and the earlier rent-control proceedings prima facie established legal possession for registration purposes.

Conclusion: A prima facie showing of legal possession is sufficient for GST registration; a landlord's unresolved dispute over tenancy rights cannot by itself justify refusal of registration.

Issues: Whether investment in a company incorporated before the statutory period, but commencing business and obtaining MSME registration during that period, qualifies for capital-gains exemption.

Analysis: The definition of an eligible company makes incorporation during the prescribed period a specific condition. The provision does not treat commencement of business, commencement of manufacturing operations, acquisition of plant and machinery, or MSME registration as substitutes for the legal date of incorporation. A beneficial construction of an incentive provision cannot override an unambiguous statutory requirement, and the claimant must fall squarely within the exemption provision.

Conclusion: A company incorporated before the prescribed period is not an eligible company merely because it remained dormant and commenced operations later; the claimed exemption was therefore unavailable to the assessee.

Issues: Whether an appeal lies before the Appellate Authority against an order of the Authority for Advance Ruling rejecting an application under the first proviso to Section 98(2).

Analysis: Section 100(1) confines appellate jurisdiction to an advance ruling pronounced under Section 98(4). The impugned ruling rejected the application under the first proviso to Section 98(2), rather than pronouncing a ruling under Section 98(4). Such rejection is therefore outside the class of rulings appealable under Section 100(1).

Conclusion: An appeal against rejection of an advance-ruling application under Section 98(2) is not maintainable before the Appellate Authority.

Issues: (i) Whether the delays in filing appeals against the intimation under section 143(1) should be condoned; (ii) Whether compensation received by BSNL employees under the Voluntary Retirement Scheme-2019 is exempt as retrenchment compensation under section 10(10B) of the Income-tax Act, 1961.

Issue (i): Whether the delays in filing appeals against the intimation under section 143(1) should be condoned.

Analysis: The delays were attributable to the assessees becoming aware of favourable decisions concerning the tax treatment of BSNL VRS-2019 compensation, coupled with incorrect professional advice and ignorance of the available exemption. On identical facts, delays of comparable and greater duration had been condoned by appellate authorities and coordinate benches. Consistent treatment required condonation.

Conclusion: The delays in filing the appeals were condoned, in favour of the assessees.

Issue (ii): Whether compensation received by BSNL employees under the Voluntary Retirement Scheme-2019 is exempt as retrenchment compensation under section 10(10B) of the Income-tax Act, 1961.

Analysis: The claims for exemption had been rejected on technical grounds without examination on merits. Coordinate benches had consistently treated the ex-gratia compensation paid under the Government-approved BSNL VRS-2019 scheme as having the character of retrenchment compensation and eligible for exemption under section 10(10B). No contrary basis warranted departure from that consistent view.

Conclusion: The BSNL VRS-2019 compensation is exempt under section 10(10B) of the Income-tax Act, 1961, in favour of the assessees.

Final Conclusion: The assessing authority must verify the individual claims, grant the applicable exemption, and determine consequential tax refund and admissible interest in accordance with law.

Ratio Decidendi: Compensation under BSNL VRS-2019, where its character is substantively retrenchment compensation, qualifies for exemption under section 10(10B) notwithstanding that the exemption was not claimed in the original return.

Issues: Whether stamp-duty valuation of a registered tenancy agreement could be adopted as the full value of consideration under section 50C for computing long-term capital gains.

Analysis: Section 50C permits substitution of stamp-duty value only where a capital asset being land, building or both is transferred for consideration lower than that value. The registered document was a tenancy agreement providing for monthly rent of Rs. 375, and the record contained no evidence of receipt or accrual of any premium, pagadi, or other consideration corresponding to the stamp-duty valuation. Valuation adopted solely to determine stamp duty cannot, without material establishing a transfer of ownership rights and actual consideration, be presumed to be consideration for capital-gains purposes.

Conclusion: Section 50C was inapplicable; the stamp-duty valuation could not be treated as the full value of consideration, and the long-term capital-gains addition was deleted in favour of the assessee.

Issues: (i) Whether an assessment framed solely pursuant to revisional directions under section 263 could survive after the revisional order was quashed; (ii) Whether interest received on fixed deposits and loans was assessable as business income, permitting set-off of brought-forward business losses.

Issue (i): Whether an assessment framed solely pursuant to revisional directions under section 263 could survive after the revisional order was quashed.

Analysis: The consequential assessment derived its sole jurisdiction and existence from the revisional order. Since that foundational revisional order had already been annulled, the consequential assessment had no independent basis to survive.

Conclusion: The consequential assessment could not survive after quashing of the revisional order, in favour of the assessee.

Issue (ii): Whether interest received on fixed deposits and loans was assessable as business income, permitting set-off of brought-forward business losses.

Analysis: The interest-bearing funds had a direct nexus with the real-estate development business, having been generated from business operations and temporarily deployed pending their utilisation for project activities. The earlier coordinate-bench decision in the assessee's case had already accepted the interest as business income, and no distinguishing feature was established.

Conclusion: The interest was assessable as business income and the brought-forward business losses were eligible for set-off, in favour of the assessee.

Final Conclusion: The appellate relief treating the interest receipts as business income and recognising the invalidity of the consequential assessment was sustained.

Ratio Decidendi: A consequential assessment founded exclusively on a revisional order cannot subsist once that foundational revisional order is annulled.