Issues: Whether exemption or reduction of the mandatory pre-deposit for filing a customs appeal could be granted on the ground of lack of funds.

Analysis: Section 129(E) of the Customs Act, 1962 mandates pre-deposit for maintaining an appeal. The applicable precedent establishes that neither the Commissioner nor the CESTAT has power to admit an appeal without such pre-deposit. Financial inability alone did not establish an exceptional case warranting interference.

Conclusion: Exemption or reduction of the mandatory pre-deposit was declined; the issue was decided against the assessee.

Issues: Whether the enhanced leave-encashment exemption ceiling of Rs. 25,00,000 under Section 10(10AA) is available for Assessment Year 2021-22 under Notification No. 31/2023.

Analysis: The enhancement from Rs. 3,00,000 to Rs. 25,00,000 was treated as a beneficial and curative measure addressing hardship caused by the prolonged non-revision of the exemption limit. Beneficial fiscal measures intended to remove unintended hardship receive liberal construction and may apply to pending proceedings unless retrospective application is specifically prohibited. The stated effective date in the notification did not preclude extending the curative benefit to the pending assessment.

Conclusion: The enhanced exemption ceiling applies to Assessment Year 2021-22, and the entire leave-encashment amount of Rs. 10,35,184 is exempt under Section 10(10AA).

Issues: Whether reassessment under Sections 147 and 148, after an original scrutiny assessment under Section 143(3), was invalid as being founded merely on a change of opinion concerning loan transactions.

Analysis: The loan transaction, its repayment, and supporting material concerning the lender's identity, creditworthiness and the genuineness of the transaction had been furnished during the original scrutiny assessment. Reopening on the same material, without any new tangible basis, amounted to a change of opinion and could not sustain reassessment jurisdiction.

Conclusion: The reassessment was invalid and was quashed, in favour of the assessee.

Issues: (i) Whether the addition for unsecured loans under Section 68 of the Income-tax Act, 1961 could be sustained where part represented opening balances, loans were received through banking channels, and repayments were undisputed; (ii) Whether credits in the assessee's capital account received from the deceased father's bank account were unexplained under Section 68 of the Income-tax Act, 1961; (iii) Whether a gross-profit rate of 2.82% could be applied after rejection of accounts under Section 145(3) of the Income-tax Act, 1961.

Issue (i): Whether the addition for unsecured loans under Section 68 of the Income-tax Act, 1961 could be sustained where part represented opening balances, loans were received through banking channels, and repayments were undisputed.

Analysis: Section 68 applies to sums credited in the books during the relevant year and does not extend to balances brought forward from preceding years. The material included creditor particulars, confirmations and income-tax returns in several cases. Banking-channel receipts established genuineness, and subsequent repayments not doubted could not support an addition to that extent. For the remaining credits, verification of lenders' creditworthiness through statutory enquiry under Section 133(6) was required.

Conclusion: No addition under Section 68 may be made for the identified opening balances and the undisputed banking-channel loans and repayments; the balance requires fresh verification. The issue is decided in favour of the assessee to that extent.

Issue (ii): Whether credits in the assessee's capital account received from the deceased father's bank account were unexplained under Section 68 of the Income-tax Act, 1961.

Analysis: The transfers from the father's bank account after his death were not disputed, although verification of the father's financial statements and availability of capital funds remained necessary. The source of the capital credit required examination from the father's records before treating it as unexplained.

Conclusion: The capital-credit addition requires fresh source verification and cannot be made if the transfer from the father's available capital is verified. The issue is decided in favour of the assessee subject to verification.

Issue (iii): Whether a gross-profit rate of 2.82% could be applied after rejection of accounts under Section 145(3) of the Income-tax Act, 1961.

Analysis: A decline in gross-profit rate, by itself, is insufficient to reject book results or apply the preceding year's rate; objective and cogent grounds are necessary. The substantial increase in turnover had resulted in higher gross profit and net profit in absolute terms, though the decline in rate was not fully explained. A gross-profit rate of 2.5% was found fair and reasonable.

Conclusion: The trading addition must be recomputed by applying a gross-profit rate of 2.5% instead of 2.82%. The issue is decided partly in favour of the assessee.

Final Conclusion: The unexplained-credit additions require verification consistent with the identified sources and evidence, while the trading profit is to be recomputed at the reduced gross-profit rate.

Issues: (i) Whether the functional comparability of the two disputed companies for benchmarking freight-forwarding transactions under the Transactional Net Margin Method required fresh functions, assets and risks analysis; (ii) Whether the assessee's claim for a working capital adjustment could be admitted and examined despite not having been raised before the Dispute Resolution Panel.

Issue (i): Whether the functional comparability of the two disputed companies for benchmarking freight-forwarding transactions under the Transactional Net Margin Method required fresh functions, assets and risks analysis.

Analysis: Comparable selection under the Transactional Net Margin Method must be based on functions, assets and risks analysis. Broad functional similarity alone was insufficient where the material relevant to the comparables' actual functions, assets deployed and risks assumed required verification for the contemporaneous period.

Conclusion: In favour of the assessee, the comparability of both disputed companies was restored to the Dispute Resolution Panel for fresh adjudication after contemporaneous functions, assets and risks analysis and an opportunity of hearing.

Issue (ii): Whether the assessee's claim for a working capital adjustment could be admitted and examined despite not having been raised before the Dispute Resolution Panel.

Analysis: A working capital adjustment under Rule 10B(3) is relevant where it enhances comparability between the tested party and the selected comparables. The claim required examination on merits notwithstanding its omission from the objections before the Dispute Resolution Panel.

Conclusion: In favour of the assessee, the working capital adjustment ground was admitted and restored to the Dispute Resolution Panel for a merits determination after an opportunity of hearing.

Final Conclusion: The contested transfer-pricing comparability and working capital adjustment questions require fresh reasoned determination by the Dispute Resolution Panel.

Ratio Decidendi: A comparable under the Transactional Net Margin Method cannot be retained merely on broad functional similarity where a contemporaneous functions, assets and risks analysis is required.

Issues: (i) Whether the delay in filing Form No. 10AB for regular approval under section 80G could be condoned; (ii) Whether absence of an express irrevocability or dissolution clause and the answer in Form No. 10AB constituted grounds to reject the application.

Issue (i): Whether the delay in filing Form No. 10AB for regular approval under section 80G could be condoned.

Analysis: The assessee held provisional approval and no finding indicated deliberate suppression, contumacious conduct, or an attempt to obtain an unintended benefit. The rejection would deny examination of substantive eligibility solely because of a procedural lapse, despite the practical difficulties associated with the revised approval regime and its transitional timelines.

Conclusion: The delay in filing Form No. 10AB was condoned, in favour of the assessee.

Issue (ii): Whether absence of an express irrevocability or dissolution clause and the answer in Form No. 10AB constituted grounds to reject the application.

Analysis: A public charitable trust is irrevocable by operation of law unless its constitutional document positively reserves a power of revocation, re-transfer of income or assets, or re-assumption of control. Mere absence of an express irrevocability declaration does not make the trust revocable. Further, an affirmative answer regarding irrevocability in Form No. 10AB could not, merely for want of an express clause, be regarded as false or incorrect information or a specified violation.

Conclusion: The absence of an express irrevocability or dissolution clause and the answer in Form No. 10AB could not independently justify rejection of the application, in favour of the assessee.

Final Conclusion: The application must be considered afresh on substantive eligibility, including charitable objects, genuineness of activities, and compliance with the statutory conditions for approval, after an effective opportunity of hearing.

Ratio Decidendi: A procedural delay without culpable conduct should not defeat adjudication of a charitable institution's substantive eligibility, and a public charitable trust is not revocable merely because its instrument lacks an express irrevocability clause.

Issues: (i) Whether the admitted payment made under the consortium arrangement towards supply of goods constituted an operational debt; (ii) Whether a pre-existing dispute barred admission of the application under Section 9 of the Insolvency and Bankruptcy Code, 2016.

Issue (i): Whether the admitted payment made under the consortium arrangement towards supply of goods constituted an operational debt.

Analysis: Section 5(21) covers a claim having nexus with provision of goods or services and does not require that the claimant must necessarily be the supplier. The consortium agreement expressly allocated to the corporate debtor the supply, installation and commissioning of specified items, while requiring payment to it for supplies and services within its scope. The admitted receipt of the amount, the unsupported nature of the security-deposit defence, issuance of cheques for the amount, and the invoice uploaded by the corporate debtor for supplies supported the existence of an inter se commercial transaction for supply of goods.

Conclusion: The payment was an advance towards supply of goods and constituted an operational debt; this issue was decided in favour of the Appellant.

Issue (ii): Whether a pre-existing dispute barred admission of the application under Section 9 of the Insolvency and Bankruptcy Code, 2016.

Analysis: The real nature of the written arrangement established a supply-related obligation. No material showed a dispute existing before the demand notice; the response after receipt of the notice merely referred to reconciliation of accounts and did not controvert the asserted basis of the advance. The later assertions concerning security deposit, non-delivery of cheques, and invoices did not establish a pre-existing dispute.

Conclusion: No pre-existing dispute was established, and it did not bar the Section 9 application; this issue was decided in favour of the Appellant.

Final Conclusion: The prior rejection was unsustainable because the operational debt exceeded the statutory threshold. The Section 9 proceeding was revived for admission, while permitting closure if the debt is liquidated within the stipulated period.

Ratio Decidendi: A claim arising from an advance paid under a consortium agreement for goods or services is an operational debt where the agreement and surrounding material establish an inter se supply obligation, and unsubstantiated post-demand assertions do not constitute a pre-existing dispute.

Issues: (i) Whether the transfer price of electricity supplied by the eligible captive power unit to the non-eligible unit could be benchmarked at the tariff charged by the distribution company to industrial consumers for determining deduction under section 80IA. (ii) Whether steam transferred by the eligible unit to the non-eligible unit could be valued at nil or at its cost of production for determining deduction under section 80IA.

Issue (i): Whether the transfer price of electricity supplied by the eligible captive power unit to the non-eligible unit could be benchmarked at the tariff charged by the distribution company to industrial consumers for determining deduction under section 80IA.

Analysis: For a specified domestic transaction, market value is arm's length price. The binding precedent and the assessee's own earlier years established that the rate charged by a State electricity distribution company to industrial consumers is an appropriate comparable uncontrolled price for captive power supplied to the consuming unit. The IEX rate represents short-term traded power and is materially dissimilar from continuous electricity supplied for consumption. The amendment concerning arm's length price did not displace this approach. No material change in facts from the earlier years was shown.

Conclusion: The electricity transferred to the non-eligible unit is to be valued at the tariff charged by MVVNL to industrial consumers; the adjustment on power transfer is deleted and the consequential deduction under section 80IA is allowable, in favour of the assessee.

Issue (ii): Whether steam transferred by the eligible unit to the non-eligible unit could be valued at nil or at its cost of production for determining deduction under section 80IA.

Analysis: Steam is a commercially valuable form of power and a distinct utility having an ascertainable production cost. The prior orders in the assessee's case, consistently with jurisdictional precedent, accepted valuation of inter-unit steam transfer at cost of production and rejected the premise that steam is merely a by-product with nil cost. The factual position remained unchanged.

Conclusion: Steam transferred to the non-eligible unit must be valued at its cost of production and not at nil; the adjustment on steam transfer is deleted and the consequential deduction under section 80IA is allowable, in favour of the assessee.

Final Conclusion: The eligible-unit profits are to be computed by accepting the assessee's valuation of captive power at the industrial-consumer tariff and steam at production cost, restoring the claimed deduction.

Ratio Decidendi: For captive inter-unit transfers forming specified domestic transactions, arm's length price may be determined by the tariff payable by the consuming unit to the distribution company for electricity, while steam, being a separately valuable utility, cannot be assigned a nil value and must be valued at its production cost.

Issues: (i) Whether the petitioner acquired an indefeasible right to default bail because the supplementary complaint, though filed within the prescribed period, was returned for compliance; (ii) Whether the petitioner satisfied the conditions for regular bail under the Prevention of Money Laundering Act.

Issue (i): Whether the petitioner acquired an indefeasible right to default bail because the supplementary complaint, though filed within the prescribed period, was returned for compliance.

Analysis: The supplementary complaint had been filed within the prescribed period. Its subsequent return for compliance did not, in the circumstances, create an indefeasible right to bail. The precedent concerning incomplete charge-sheets filed to defeat default bail was factually distinguishable.

Conclusion: The petitioner was not entitled to default bail. This finding is against the petitioner.

Issue (ii): Whether the petitioner satisfied the conditions for regular bail under the Prevention of Money Laundering Act.

Analysis: The material prima facie indicated the petitioner's involvement in activities connected with proceeds of crime, including alleged interference with the investigation and auction of attached properties. The Court was not satisfied that there were reasonable grounds to believe that the petitioner was not guilty or that he would not commit an offence while on bail, as required by the twin conditions.

Conclusion: The petitioner did not satisfy the statutory conditions for grant of bail. This finding is against the petitioner.

Final Conclusion: Bail was unavailable because neither default-bail entitlement nor the statutory threshold for release in a money-laundering offence was established.

Ratio Decidendi: Filing of a supplementary complaint within the prescribed period is not rendered ineffective for default-bail purposes merely because it is returned for procedural compliance, and bail under the money-laundering regime requires satisfaction of the statutory twin conditions.

Issues: Whether the petitioner could submit a physical application for revocation of cancellation of GST registration despite expiry of the statutory period.

Analysis: In view of the stated circumstances and the expiry of the period for pursuing the ordinary statutory remedy, the petitioner was permitted to approach the competent authority with a physical application for revocation. The authority was required to entertain the application and decide it in accordance with law within the stipulated period.

Conclusion: The petitioner may submit the physical revocation application within two weeks, and the competent authority shall decide it within three weeks thereafter.

Issues: Whether paper bags made of paper or paperboard, classifiable under Tariff Item 48194000, attract GST at 5% under Entry 319 of Schedule I or 18% under Entry 185 of Schedule II of Notification No. 09/2025-Central Tax (Rate).

Analysis: Paper sacks and bags manufactured from paper are specifically classifiable under Tariff Item 48194000 of Heading 4819. Entry 319 of Schedule I expressly covers paper sacks/bags under Chapters 39 and 48. Its insertion, viewed in the context of the GST Council deliberations, reflects the intended promotion of paper bags and biodegradable bags as environmentally friendly alternatives to conventional plastic bags. The conjunction joining paper sacks/bags and biodegradable bags does not restrict the entry only to paper bags that are themselves biodegradable.

Conclusion: Paper bags classifiable under Tariff Item 48194000 are covered by Entry 319 of Schedule I to Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 and attract GST at 5%, in favour of the assessee.

Issues: Whether the Commissioner (Appeals) could set aside and remand an assessment made under section 147 read with section 144B for fresh assessment under the proviso to section 251(1)(a).

Analysis: The proviso to section 251(1)(a), restored with effect from 01.10.2024, authorises the Commissioner (Appeals) to set aside an assessment and direct a fresh assessment only where the assessment was made under section 144. The assessment in question was expressly made under section 147 read with section 144B and could not be treated as a best judgment assessment under section 144 merely because the assessee's submissions were unavailable or illegible on the portal.

Conclusion: The Commissioner (Appeals) lacked jurisdiction to set aside the assessment and remit it to the Assessing Officer; the appellate order was set aside and the appeal was restored to the Commissioner (Appeals) for fresh decision on the grounds raised.

Issues: Whether the petitioner was entitled to anticipatory bail in a money-laundering investigation, including on medical grounds.

Analysis: The material at the investigation stage indicated that the petitioner allegedly facilitated the award of a sub-contract to an entity connected with his son and that the alleged proceeds were transferred to family members. The absence of a direct credit to the petitioner's account was not determinative. The allegations, financial material and need to trace the money trail required further investigation; at the pre-arrest bail stage, the evidence was not to be assessed conclusively. The statutory twin conditions for bail were not capable of being satisfied in the petitioner's favour at that stage. The available medical record did not establish a continuing serious condition, medical emergency, or urgent intervention warranting protection from arrest.

Conclusion: The petitioner was not entitled to anticipatory bail, either on merits or medical grounds.

Issues: Whether the pending rectification application required a direction for time-bound disposal.

Analysis: The authority accepted that reasonable time could be granted to decide the pending rectification application.

Conclusion: The rectification application shall be considered and disposed of within six weeks from receipt of the order.

Issues: Whether a six-day delay in filing the statutory appeal should be condoned and the appeal restored for fresh consideration.

Analysis: The appellate authority failed to account for the bona fide circumstances in which the petitioner, appearing without legal assistance, neither filed a delay-condonation application nor articulated proper grounds. The short delay was attributable to sufficient cause, and an opportunity to prosecute the appeal through counsel was warranted under a justice-oriented approach.

Conclusion: The six-day delay was condoned, and the appellate order was set aside with restoration of the appeal for fresh decision on merits.

Issues: (i) Whether CENVAT credit was admissible on supplementary invoices issued after detection of the service provider's prior non-payment of service tax; (ii) Whether penalty for wrongful availment of such credit was imposable on the appellant.

Issue (i): Whether CENVAT credit was admissible on supplementary invoices issued after detection of the service provider's prior non-payment of service tax.

Analysis: Rule 9(1)(bb) of the Cenvat Credit Rules, 2004 excludes credit on supplementary invoices where the additional tax became recoverable because of non-levy or non-payment occasioned by fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade tax. The service provider issued the supplementary invoices and paid the tax only after departmental detection of the earlier non-payment. The Settlement Commission's grant of only partial immunity, accompanied by reduction rather than elimination of penalty, established that the non-payment fell within the exclusion contemplated by Rule 9(1)(bb).

Conclusion: CENVAT credit on the supplementary invoices was inadmissible, and the denial of credit with interest was sustained against the assessee.

Issue (ii): Whether penalty for wrongful availment of such credit was imposable on the appellant.

Analysis: The invoices relied upon for credit contained the prescribed particulars, including duty payment and taxable value. There was no omission attributable to the appellant in availing credit on those documents.

Conclusion: Penalty under Rule 15(2) of the Cenvat Credit Rules, 2004 read with Section 11AC of the Central Excise Act, 1944 was not imposable; this issue was decided in favour of the assessee.

Final Conclusion: The statutory bar to credit arising from the service provider's tax evasion applies, but penal liability of the recipient requires an omission or culpable conduct attributable to that recipient.

Ratio Decidendi: Credit on supplementary invoices is barred under Rule 9(1)(bb) where the supplier's additional tax liability arose from fraud, suppression, or like conduct with intent to evade tax; penalty on the credit recipient cannot be imposed absent culpable omission by that recipient.

Issues: (i) Whether the deletion of the addition representing 12.5% of alleged bogus purchases for assessment year 2018-19 was justified; (ii) Whether additions for alleged non-genuine purchases, estimated gross profit and unexplained GST component in respect of transactions with the supplier for assessment year 2019-20 were sustainable; (iii) Whether penalty for under-reporting and misreporting of income could survive after deletion of the quantum addition.

Issue (i): Whether the deletion of the addition representing 12.5% of alleged bogus purchases for assessment year 2018-19 was justified.

Analysis: The purchases were supported by invoices, transport records, banking-channel payments, supplier confirmation, GST material and stock records. The corresponding sales and books of account were not disturbed. The supplier's registration was cancelled only subsequently, and the assessing authority did not pursue verification from the resolution professional despite the supplier being under insolvency proceedings. Similar transactions with the supplier had also been accepted by the Revenue in other cases.

Conclusion: The purchases were genuine and the ad hoc addition of 12.5% was unjustified, in favour of the assessee.

Issue (ii): Whether additions for alleged non-genuine purchases, estimated gross profit and unexplained GST component in respect of transactions with the supplier for assessment year 2019-20 were sustainable.

Analysis: The purchase and sale transactions were reconciled with the supplier's records and supported by invoices, e-way bills, stock records, GST returns and banking-channel payments. The Revenue produced no cogent evidence of fictitious transactions, cash return of GST, or unexplained money. The additions for estimated profit and GST were made without rejection of books and, for the GST component, without a specific opportunity to respond. The assessing authority did not make adequate further inquiry from the resolution professional or the records available with GST authorities.

Conclusion: The additions under Sections 69C and 69A, including estimated profit and alleged unexplained GST, were unsustainable, in favour of the assessee.

Issue (iii): Whether penalty for under-reporting and misreporting of income could survive after deletion of the quantum addition.

Analysis: The penalty was founded solely on the quantum addition concerning the alleged bogus purchases. Since that addition was deleted on merits and the deletion was upheld, the foundation for penalty ceased to exist.

Conclusion: The penalty under Section 270A could not survive, in favour of the assessee.

Final Conclusion: The substantive additions based on the alleged non-genuine transactions with the supplier and the consequential penalty stand extinguished; the assessee's legal objections in the cross-objections were left unadjudicated as academic.

Ratio Decidendi: Additions for alleged bogus purchases or sales cannot rest on general information, retrospective cancellation of a supplier's registration, or estimation alone where the assessee substantiates the transactions through contemporaneous records and the Revenue fails to conduct effective contrary inquiry.

Issues: Whether dismissal of the appeal as time-barred without granting the repeatedly requested virtual personal hearing violated principles of natural justice.

Analysis: The assessee had explained that the delay resulted from pursuing a writ remedy and had repeatedly sought a virtual hearing to explain the delay. No hearing was granted before the appeal was dismissed in limine. The delay attributable to pursuing an alternative remedy could constitute sufficient cause depending on the facts. Paragraph 13 of the e-Appeals Scheme, 2023 mandates that a requested personal hearing be allowed through video conferencing or video telephony.

Conclusion: The dismissal without affording the requested hearing violated principles of natural justice; the appellate order was set aside and the appeal was remanded for fresh adjudication after providing a personal hearing.

Issues: (i) Whether electricity transferred from eligible captive power units to non-eligible units could be benchmarked at the State Electricity Board supply rate rather than the Indian Energy Exchange rate with an ad hoc markup; (ii) Whether the arm's length price of steam transferred from eligible units to non-eligible units could be determined at nil; (iii) Whether the transfer-pricing adjustment for sale of hybrid seeds required fresh benchmarking using transactional TNMM after accounting for extraordinary business conditions; (iv) Whether adjustment of interest on foreign-currency loans to an associated enterprise was justified; (v) Whether sale consideration of a depreciable building could be added separately despite its adjustment against the block of assets; and (vi) Whether claimed tax-rate, MAT-credit, TCS-credit and demand-adjustment errors required verification and rectification.

Issue (i): Whether electricity transferred from eligible captive power units to non-eligible units could be benchmarked at the State Electricity Board supply rate rather than the Indian Energy Exchange rate with an ad hoc markup.

Analysis: The State Electricity Board rate was an appropriate external CUP because it reflected the price that the consuming unit would have paid for regular electricity supply. Electricity traded on the Indian Energy Exchange was materially dissimilar, being short-term, volatile and not a source of uninterrupted power. The ad hoc 30% markup had no basis. The jurisdictional High Court's decision in the assessee's own case was binding; its operation could not be disregarded merely because the Revenue contemplated filing a special leave petition.

Conclusion: The electricity transfer-pricing adjustment was deleted in favour of the assessee.

Issue (ii): Whether the arm's length price of steam transferred from eligible units to non-eligible units could be determined at nil.

Analysis: Steam was a commercially valuable product with an ascertainable production cost and could not be treated as having nil value merely because it arose in power generation. Binding decisions in the assessee's earlier years had accepted cost-based valuation of steam. The revenue authorities were required to follow those binding decisions unless stayed by a competent court.

Conclusion: The steam transfer-pricing adjustment was deleted in favour of the assessee.

Issue (iii): Whether the transfer-pricing adjustment for sale of hybrid seeds required fresh benchmarking using transactional TNMM after accounting for extraordinary business conditions.

Analysis: Extraordinary reductions in volume, inventory provisioning and seed discard costs adversely affected profitability. Transactional TNMM was more appropriate than entity-level TNMM where the international transaction represented a small proportion of total sales and reliable transactional workings were available. The assessee had not received adequate opportunity regarding its transactional profitability and comparable analysis. The Transfer Pricing Officer was directed to verify transactional TNMM, the assessee's and comparables' PLIs, and appropriate adjustments for extraordinary circumstances.

Conclusion: The hybrid-seed adjustment was restored for fresh determination in accordance with the prescribed transactional benchmarking methodology, favouring the assessee.

Issue (iv): Whether adjustment of interest on foreign-currency loans to an associated enterprise was justified.

Analysis: LIBOR was the appropriate benchmark for a foreign-currency loan. Further, the variation fell within the statutory tolerance range.

Conclusion: The interest adjustment was deleted in favour of the assessee.

Issue (v): Whether sale consideration of a depreciable building could be added separately despite its adjustment against the block of assets.

Analysis: Sale proceeds of a depreciable building are required to be adjusted against the written down value of the relevant block of assets. A separate addition would result in double taxation if the sale consideration had already been reduced from that block. Verification of the assessee's claim was necessary.

Conclusion: The issue was restored to verify the block-of-assets treatment; no addition is to survive if the claim is verified.

Issue (vi): Whether claimed tax-rate, MAT-credit, TCS-credit and demand-adjustment errors required verification and rectification.

Analysis: The asserted computation errors were capable of verification from the record, including the applicable rate on capital gains, MAT credit, TCS credit and adjustment of a demand that had ceased to survive.

Conclusion: The Assessing Officer was directed to verify and rectify the computation claims in accordance with law.

Final Conclusion: The substantive electricity, steam and foreign-currency-loan adjustments do not survive; the hybrid-seed, property-sale and computation matters require fresh verification or recomputation on the stated legal basis.

Ratio Decidendi: Revenue authorities must follow binding jurisdictional precedent unless it is stayed, and transfer-pricing comparables must be materially comparable to the tested transaction, with reliable transactional analysis preferred where entity-level results are distorted by extraordinary circumstances.

Issues: Whether the delay in filing audit reports in Form 10B for claiming exemption for the relevant assessment years should be condoned under Section 119(2)(b) of the Income-tax Act, 1961.

Analysis: Section 119(2)(b) does not itself prescribe a period for seeking condonation and empowers the authorities to admit a belated claim to avoid genuine hardship. Although the revenue authorities were bound by the CBDT circular prescribing a time limit, the petitioner established sufficient cause through medical records, age and the fact that the audit reports were filed only a few days after the returns. The petitioner was not entirely free from responsibility, warranting imposition of costs.

Conclusion: The delay in filing Form 10B was condoned, in favour of the assessee.

Ratio Decidendi: A belated claim may be condoned under Section 119(2)(b) where the facts establish sufficient cause and genuine hardship, notwithstanding that the provision itself fixes no limitation period.