Issues: Whether the contempt order and consequential civil imprisonment could be sustained when the Adjudicating Authority had not first recorded prima facie satisfaction of contempt, had not issued a proper show-cause notice with precise charges, and had not identified the specific individual contemnors.

Analysis: Contempt proceedings, especially where penal consequences such as imprisonment are imposed, require strict compliance with the settled two-stage procedure. The court must first form a prima facie view that wilful and deliberate disobedience is made out, then communicate the specific allegations through a meaningful show-cause notice so that the alleged contemnors know the case they must meet. A routine notice, without framed charges, is insufficient. Where the alleged default is attributable to corporate entities and the sanction letters were issued separately by different banks on varying terms, punishment cannot be imposed in a composite manner without identifying the individual officers alleged to have committed contempt. The absence of such foundational procedural safeguards renders the contempt determination unsustainable.

Conclusion: The contempt order was held unsustainable for want of the mandatory procedural safeguards, and the appeal succeeded.

Issues: (i) Whether the demand for the disputed service tax period could be sustained beyond the normal period of limitation and whether the penalty under section 78 was justified; (ii) Whether the appellant was entitled to cum-tax benefit while computing taxable value; (iii) Whether the matter required remand for reconsideration of exemption and re-quantification.

Issue (i): Whether the demand for the disputed service tax period could be sustained beyond the normal period of limitation and whether the penalty under section 78 was justified.

Analysis: The Tribunal treated limitation as a jurisdictional issue capable of examination even if not squarely pleaded in the appeal memorandum. It held that invocation of the extended period requires the ingredients of fraud, wilful misstatement, suppression of facts or contravention with intent to evade tax. Mere non-payment, without material showing deliberate evasion, is insufficient. On the facts, no such allegation was discernible in the notices, and the material on record did not justify sustaining the penalty under section 78. The demand beyond the normal period was therefore not maintainable.

Conclusion: The extended period could not be upheld, the penalty under section 78 was unsustainable, and the demand was confined to the normal period.

Issue (ii): Whether the appellant was entitled to cum-tax benefit while computing taxable value.

Analysis: The Tribunal applied section 67(2) of the Finance Act, 1994 and held that, where service tax is not separately recovered, the consideration received must ordinarily be treated as inclusive of tax. It found no material showing separate collection of service tax or that the gross receipts were not inclusive of tax. Accordingly, the taxable value had to be reworked on a cum-tax basis.

Conclusion: The appellant was entitled to cum-tax benefit while determining the service tax liability.

Issue (iii): Whether the matter required remand for reconsideration of exemption and re-quantification.

Analysis: The Tribunal directed the Original Authority to examine the claim of exemption under Notification No. 25/2012-Service Tax dated 20.06.2012 and to keep in view Circular No. 200/10/2016-Service Tax dated 06.09.2016. It also directed that, if the service was held taxable, the demand would be restricted to the normal period and the benefit of exclusion of municipal taxes and cum-tax valuation would be applied in quantification. The appeal was therefore disposed of by sending the matter back for fresh adjudication in accordance with law and after affording hearing.

Conclusion: The matter was remanded to the Original Authority for fresh decision and quantification.

Final Conclusion: The impugned order was set aside in part, the assessee obtained relief on limitation, penalty and cum-tax valuation, and the remaining issues were sent back for fresh adjudication by the Original Authority.

Ratio Decidendi: In service tax matters, the extended period and penal consequences require proof of deliberate suppression or intent to evade, and where tax is not separately recovered the gross consideration is to be treated as inclusive of service tax for valuation.

Issues: (i) Whether further investigation could be undertaken after closure reports had been filed without express permission of the Magistrate; (ii) Whether the dispute was essentially civil in nature so as to render criminal prosecution an abuse of process of law.

Issue (i): Whether further investigation could be undertaken after closure reports had been filed without express permission of the Magistrate.

Analysis: The text of Section 173(8) of the Code of Criminal Procedure, 1973 does not expressly require prior leave, but the settled judicial understanding has read such permission into the provision as a necessary implication. Where further investigation is sought after earlier closure and the record does not disclose any order granting permission, the investigation cannot be sustained on the basis that leave is unnecessary.

Conclusion: Further investigation without the Magistrate's approval was impermissible and the resulting criminal proceedings were liable to be quashed.

Issue (ii): Whether the dispute was essentially civil in nature so as to render criminal prosecution an abuse of process of law.

Analysis: The controversy arose from a business arrangement concerning investment, supply of goods and sharing of profits, which disclosed a commercial disagreement over the existence and terms of a joint venture. The allegations of forgery were also found to be suspect in light of their timing and the earlier civil proceedings, and the criminal process could not be used to convert a civil dispute into a prosecution.

Conclusion: The dispute was civil in character and the criminal case amounted to an abuse of process of law.

Final Conclusion: The FIR, chargesheet and ensuing proceedings were set aside, and the appeal succeeded.

Ratio Decidendi: Further investigation after closure of the police case requires judicial leave as a necessary implication of Section 173(8) CrPC, and a predominantly civil commercial dispute cannot be pursued through criminal prosecution when the criminal allegations do not independently sustain.

Issues: (i) whether the complaint disclosed sufficient foundational averments and material to proceed against respondents 1, 2 and 4 under Section 141 of the Negotiable Instruments Act, 1881; (ii) whether respondent 3 could be proceeded against on the basis of a mere office-bearer designation without specific factual linkage to the transaction.

Issue (i): Whether the complaint disclosed sufficient foundational averments and material to proceed against respondents 1, 2 and 4 under Section 141 of the Negotiable Instruments Act, 1881

Analysis: Vicarious liability under Section 141 requires specific averments that the accused was in charge of and responsible for the conduct of the business at the relevant time. The complaint must be read as a whole, and the absence of mechanical reproduction of statutory language is not fatal if the factual foundation is otherwise discernible. Here, the complaint and accompanying documents referred to antecedent borrowings, promissory notes, the memorandum of understanding, and the cheque transaction. The material prima facie showed participation of respondents 1, 2 and 4 in the underlying financial dealings, which was sufficient at the quashing stage.

Conclusion: The proceedings were rightly maintainable against respondents 1, 2 and 4.

Issue (ii): Whether respondent 3 could be proceeded against on the basis of a mere office-bearer designation without specific factual linkage to the transaction

Analysis: Mere designation as an office bearer does not by itself attract liability under Section 141. The complaint did not attribute any specific role to respondent 3, nor did any document show his participation in the transaction. In the absence of a factual foundation connecting him with the dishonoured cheque transaction, prosecution could not be sustained against him.

Conclusion: The proceedings against respondent 3 were liable to remain quashed.

Final Conclusion: The impugned quashing order was interfered with only to the extent of respondents 1, 2 and 4, while the quashing in favour of respondent 3 was affirmed, and the complaint stood revived against respondents 1, 2 and 4 alone.

Ratio Decidendi: For prosecution under Section 141 of the Negotiable Instruments Act, 1881, the complaint must disclose specific foundational facts showing that each accused was in charge of and responsible for the conduct of the business; however, where the complaint read as a whole and the supporting documents prima facie show participation in the transaction, threshold quashing is unwarranted, while a bare office-bearer designation without factual linkage is insufficient.

Issues: Whether enhancement of the declared import value on the basis of NIDB data and contemporaneous imports, without sufficient independent material, was legally sustainable; and whether acceptance of the enhanced duty to secure clearance barred the importer from challenging the reassessment.

Analysis: The Tribunal followed the binding view that under the customs valuation scheme, rejection of declared value and reassessment must rest on a legally sustainable reason to doubt, supported by reasons and cogent material, and cannot be founded on NIDB data alone. It further held that payment of enhanced duty under compulsion for clearance does not amount to waiver or estoppel against the importer's statutory right to dispute the reassessment. Applying that ratio, the Tribunal found the impugned enhancement unsustainable.

Conclusion: The enhancement of value was held unsustainable and the appeals were allowed in favour of the assessee.

Final Conclusion: The common re-assessment order was set aside, and the importer's challenge succeeded with consequential relief as permitted by law.

Ratio Decidendi: Declared import value cannot be rejected or enhanced merely on the basis of NIDB data or similar external comparisons unless the proper officer records a legally tenable reason to doubt and supports reassessment with cogent evidence; acceptance of enhanced duty under protest does not extinguish the importer's right to challenge the valuation.

Issues: (i) Whether the services of supply, erection, commissioning and allied activities undertaken for power substations and transmission lines were exempt as services in relation to transmission and distribution of electricity under Notification No. 45/2010-ST dated 20.07.2010; and (ii) whether the separate freight and insurance charges could be brought to tax as goods transport agency service in the absence of consignment notes.

Issue (i): Whether the services of supply, erection, commissioning and allied activities undertaken for power substations and transmission lines were exempt as services in relation to transmission and distribution of electricity under Notification No. 45/2010-ST dated 20.07.2010.

Analysis: The contracts, when read with their scope and purpose, were found to cover supply, construction, erection and commissioning of sub-stations and transmission line towers for utilities engaged in transmission and distribution of electricity. The expression "in relation to" was treated as broad enough to cover such preparatory and enabling activities connected with transmission and distribution infrastructure. The exemption notification was applied retrospectively to the relevant period, and the demand based on classification under erection, commissioning or installation service and works contract service was held unsustainable.

Conclusion: The issue was answered in favour of the assessee, and the demand relating to these services was held to be not taxable.

Issue (ii): Whether the separate freight and insurance charges could be brought to tax as goods transport agency service in the absence of consignment notes.

Analysis: The freight and insurance component was examined as part of the transportation arrangement connected with execution of the project contracts. Since consignment notes, which are central to fastening liability in goods transport agency service, were not established on record, and the demand was sought on the basis of the contractual freight figures alone, the levy was not sustained.

Conclusion: The issue was answered in favour of the assessee, and the freight and insurance demand was also held not payable.

Final Conclusion: The impugned order dropping the entire service tax demand was upheld, and the revenue appeal failed.

Ratio Decidendi: Services integrally connected with the creation of electricity transmission and distribution infrastructure fall within the exemption for services "in relation to" transmission and distribution of electricity, and a goods transport agency levy cannot be fastened without the statutory indicia required for that category.

Issues: (i) whether amounts deposited during investigation, supported by protest letters but not marked on challans, were to be treated as payment under protest for the purpose of refund; (ii) whether the refund claim was barred by limitation under Section 11B of the Central Excise Act, 1944 as made applicable to service tax; and (iii) whether the doctrine of unjust enrichment barred refund of the amount deposited.

Issue (i): whether amounts deposited during investigation, supported by protest letters but not marked on challans, were to be treated as payment under protest for the purpose of refund.

Analysis: The amount was deposited during ongoing investigation before adjudication, and the contemporaneous letters addressed to the investigating authority recorded that the deposits were made under protest. The absence of the formal protest procedure on challans did not alter the character of a payment made under compulsion during investigation.

Conclusion: The deposits were rightly treated as amounts made under protest, and the Revenue's objection on this ground failed.

Issue (ii): whether the refund claim was barred by limitation under Section 11B of the Central Excise Act, 1944 as made applicable to service tax.

Analysis: Refund was claimed after the adjudication order dropping the demand, and the period was computed from receipt of that order. Since the demand itself had been set aside and the deposits were made during investigation without final determination of liability, the claim was held to be within the statutory period.

Conclusion: The refund claim was not time-barred.

Issue (iii): whether the doctrine of unjust enrichment barred refund of the amount deposited.

Analysis: The assessee produced material showing that the burden had not been passed on to any customer, including a chartered accountant's certificate and a supporting declaration. On the facts, the amount retained by the Department could not be justified on the ground of unjust enrichment.

Conclusion: The bar of unjust enrichment did not apply.

Final Conclusion: The refund order was sustained, and the Revenue's challenge to the grant of refund failed in entirety.

Ratio Decidendi: An amount deposited during investigation, when supported by contemporaneous protest and not shown to have been passed on, retains the character of a refundable deposit and the refund cannot be denied on the ground of limitation or unjust enrichment merely because the formal protest procedure was not followed.

Issues: (i) Whether Cenvat credit was admissible on the impugned input services used in the manufacture and clearance of final products under Rule 2(l) of the Cenvat Credit Rules, 2004; (ii) Whether Cenvat credit was admissible on manpower supply for canteen service as an input service.

Issue (i): Whether Cenvat credit was admissible on the impugned input services used in the manufacture and clearance of final products under Rule 2(l) of the Cenvat Credit Rules, 2004.

Analysis: The definition of input service was read as having wide amplitude, covering services used directly or indirectly in or in relation to manufacture and clearance of final products. The Tribunal relied on its earlier decisions in the assessee's own case and on the settled position that services having nexus with manufacture or business activity fall within the inclusive scope of the definition.

Conclusion: Cenvat credit on the impugned input services was held admissible and the denial of credit was set aside in favour of the assessee.

Issue (ii): Whether Cenvat credit was admissible on manpower supply for canteen service as an input service.

Analysis: The canteen facility was treated as a statutory and cost-linked requirement in a factory having the requisite number of workers, and the manpower supplied for operating the canteen was held to be a service in relation to manufacture. The Tribunal followed the larger bench view that canteen-related expenditure forms part of the cost of production and is covered by the broad meaning of input service.

Conclusion: Cenvat credit on manpower supply for canteen service was upheld and the Revenue's appeal was rejected.

Final Conclusion: The assessee succeeded on the disputed input service credit claims, while the Revenue's challenge to the credit allowed on canteen manpower service failed, resulting in a partial allowance of the composite set of appeals.

Ratio Decidendi: Services that have a direct or indirect nexus with manufacture, clearance, or the business of production are covered by the wide inclusive scope of input service under Rule 2(l) of the Cenvat Credit Rules, 2004, and canteen-related services mandated for factory operations may also qualify when they form part of the cost of production.

Outcome: The prior ex parte appellate order was recalled and the matter was directed to be listed for fresh hearing.

Issues: Whether advances written off by an assessee engaged in financing and investment activities were allowable as bad debts.

Analysis: The record established that financing and lending formed part of the assessee's business objects and actual business activities; its accounts reflected substantial loans and advances, and there was no material showing any subsequent change in that business. The impugned advances were therefore made in the ordinary course of business and had been written off in the accounts.

Conclusion: The written-off advances were allowable as bad debts under Section 36(1)(vii) of the Income-tax Act, 1961, in favour of the assessee.

Issues: Whether the High Court could entertain a challenge concerning proceedings pending before the National Company Law Tribunal under the insolvency framework.

Analysis: The jurisdictional objection was treated as requiring consideration, with notice directed to be issued.

Outcome: Notice issued; the impugned order and further proceedings were stayed pending consideration.

Issues: Whether penalty under Section 271AAB of the Income-tax Act, 1961 was leviable where the addition arose only from valuation of stock by the departmental valuer and there was no discrepancy in the quantity of stock found during search.

Analysis: The penalty was deleted by the first appellate authority on the finding that the controversy related solely to valuation of stock and not to any difference in actual stock found. The Tribunal found no reason to interfere with that reasoned conclusion and accepted that the amount based only on the departmental valuation could not be treated as undisclosed income for the purpose of the penalty provision.

Conclusion: The penalty under Section 271AAB was not sustainable and the Revenue's appeal failed.

Ratio Decidendi: Where an addition arises only from a valuation difference in stock and not from any discrepancy in quantity or concealment of stock, such amount does not constitute undisclosed income for the purposes of penalty under Section 271AAB of the Income-tax Act, 1961.

Issues: Whether network fees received by the assessee were taxable as fees for technical services under the Income-tax Act, 1961 and Article 13 of the India-Denmark Double Tax Avoidance Agreement.

Analysis: The issue was recurring and had been decided in the assessee's favour in earlier assessment years on materially similar facts. No change in facts or law was shown. The network-fee receipts were therefore covered by the earlier decisions holding that such receipts were not fees for technical services taxable in India.

Conclusion: The network fees were not taxable as fees for technical services under the Act or Article 13 of the India-Denmark Double Tax Avoidance Agreement; the addition was deleted in favour of the assessee.

Issues: (i) Whether additions for unexplained investment in construction under section 69B, founded solely on the difference between the recorded construction cost and the Departmental Valuation Officer's estimate, were sustainable; (ii) Whether income determined through an earlier intimation under section 143(1) could be challenged in an assessment under section 153C where no fresh addition was made.

Issue (i): Whether additions for unexplained investment in construction under section 69B, founded solely on the difference between the recorded construction cost and the Departmental Valuation Officer's estimate, were sustainable.

Analysis: The valuation was based on the Plinth Area Rate and Cost Index Method because complete day-to-day construction accounts and drawings were unavailable. The difference between the recorded and estimated construction costs was about 10.99%. No evidence of unaccounted expenditure relating to the hostel construction was found in the search, and no latent, patent or glaring defect in the recorded construction cost was identified. A valuation estimate could not replace the actual recorded cost merely on that basis.

Conclusion: The additions under section 69B for the assessment years 2012-13 to 2017-18 were unsustainable and were deleted, in favour of the assessee.

Issue (ii): Whether income determined through an earlier intimation under section 143(1) could be challenged in an assessment under section 153C where no fresh addition was made.

Analysis: The assessment under section 153C merely adopted income already determined by the pre-search intimation under section 143(1), without making any addition. The proper remedies against that intimation were an appeal or rectification application. Section 153C concerns assessment of unaccounted income unearthed in search and could not be used to challenge the earlier intimation.

Conclusion: The challenge to the income determined under the earlier section 143(1) intimation was not maintainable in the section 153C assessment appeal, against the assessee.

Final Conclusion: Valuation-based construction differences, absent evidence of unrecorded expenditure or material defects in the recorded cost, cannot support unexplained-investment additions; an earlier processing intimation must be challenged through its prescribed statutory remedies.

Ratio Decidendi: A Departmental Valuation Officer's estimate alone cannot displace recorded construction expenditure for an unexplained-investment addition without evidence of unaccounted investment or identified material defects in the accounts.

Issues: Whether cash deposited in specified bank notes during demonetisation, stated to arise from recorded business receipts, could be assessed as unexplained money where the books, sales, stock records and VAT returns were not discredited.

Analysis: The assessee maintained audited books, day-wise cash book, sales and purchase registers, stock records, quantitative details and VAT returns. The recorded sales and corresponding stock movement were not disputed, no defect was identified in the underlying records, and the books were not rejected. The cash deposits during the relevant demonetisation period were lower than those in the corresponding preceding period. A higher cash balance alone, without material establishing undisclosed sources or rebutting the documentary evidence, could not displace the explanation that the deposits represented pre-demonetisation business receipts already recorded in the books.

Conclusion: The cash deposits could not be treated as unexplained money under sections 68 or 69A; deletion of the addition was directed in favour of the assessee.

Issues: (i) Whether penalty under section 271AA of the Income-tax Act, 1961 was leviable for non-reporting of the sale of raw materials to the associated enterprise in Form 3CEB; and (ii) whether the enhancement of penalty by the Commissioner (Appeals) in respect of guarantee fees and trade affairs services, not forming part of the original penalty proceedings, was sustainable.

Issue (i): Whether penalty under section 271AA of the Income-tax Act, 1961 was leviable for non-reporting of the sale of raw materials to the associated enterprise in Form 3CEB.

Analysis: The transaction was found to have been undertaken directly from Korea and not through the Indian project office or permanent establishment. No material was brought to show a nexus with the Indian project office, no income addition or profit attribution was made in the assessment, and the transaction was accepted at arm's length in the case of the Indian associated enterprise. In these circumstances, the assessee's belief that the transaction was not chargeable to tax in India and was not required to be reported was held to be bona fide. The Tribunal also applied the principle that section 271AA is subject to the statutory defence of reasonable cause under section 273B.

Conclusion: Penalty under section 271AA for non-reporting of the raw materials transaction was not leviable and the issue was decided in favour of the assessee.

Issue (ii): Whether the enhancement of penalty by the Commissioner (Appeals) in respect of guarantee fees and trade affairs services, not forming part of the original penalty proceedings, was sustainable.

Analysis: The original penalty proceedings were confined to the alleged non-reporting of the sale of raw materials. The Commissioner (Appeals) introduced additional transactions that had not been the subject matter of the Assessing Officer's penalty order. The appellate power of enhancement under section 251(1)(b) was held not to extend to a completely new source or subject matter not examined in the original penalty proceedings.

Conclusion: The enhancement of penalty in respect of guarantee fees and trade affairs services was unsustainable and was deleted, in favour of the assessee.

Final Conclusion: The appeal succeeded on merits, the penalty was deleted in full, and the ancillary stay application became infructuous.

Ratio Decidendi: Penalty for non-reporting of an international transaction is not sustainable where the assessee establishes reasonable cause and a bona fide belief that the transaction was outside the taxable/reportable ambit, and appellate enhancement cannot be used to introduce a new penal subject matter not covered by the original penalty proceedings.

Issues: Whether the transfer pricing adjustment made by determining the arm's length price of management fee paid for intra-group services at nil was sustainable.

Analysis: The Tribunal noted that the assessee had placed documentary evidence to show actual receipt of services and the group cost allocation basis. It followed the earlier decision in the assessee's own case and the settled principle that the revenue cannot disallow or nullify an international transaction merely on the ground of commercial expediency, perceived lack of necessity, or the assessee's business wisdom. It further held that where services are shown to have been rendered, the arm's length price cannot be fixed at nil without adopting a legally permissible method and without demonstrating that identical services would be available in an uncontrolled situation for nil consideration.

Conclusion: The transfer pricing adjustment was deleted and the assessee succeeded on this issue.

Issues: Whether the Assessing Officer could make corporate tax additions in the final assessment order when those additions were not part of the original draft assessment order and were not covered by any directions of the Dispute Resolution Panel; and whether a second draft assessment order issued after objections before the Panel was valid.

Analysis: Section 144C of the Income-tax Act, 1961 contemplates a single draft assessment order in the first instance, against which the eligible assessee may raise objections before the Dispute Resolution Panel. The Panel's directions are binding on the Assessing Officer, and the final assessment has to be completed in conformity with those directions. The procedure does not permit the Assessing Officer to issue a fresh or second draft assessment order in the same proceedings to introduce additional corporate tax variations after the first draft has already triggered the statutory mechanism. Additions made in the final order beyond the draft order and without DRP directions were therefore contrary to the statutory scheme.

Conclusion: The corporate tax additions made in the final assessment order were held to be illegal and liable to be deleted, and the second draft assessment order was held to be invalid.

Final Conclusion: The appeal succeeded and the assessee obtained relief on the corporate tax issue for the assessment year in question.

Ratio Decidendi: Under section 144C of the Income-tax Act, 1961, the Assessing Officer must proceed on the basis of a single draft assessment order and cannot make additions in the final assessment order beyond the proposed variations or outside the binding directions of the Dispute Resolution Panel.

Issues: Whether deduction under section 54F was admissible where the capital gain was utilised for construction and structural improvement of an existing residential house, including additional rooms and allied civil works, instead of purchase of a wholly new house.

Analysis: The provision is beneficial in nature and must be construed liberally to advance its object. The works undertaken were not confined to routine repairs; they included structural additions and other construction activities, supported by an engineer's certificate and related evidence. The Revenue did not disprove the genuineness of the expenditure. The fact that deduction under the same provision had been claimed in an earlier year for purchase of the residential property did not, by itself, bar relief for subsequent capital gain invested in further construction and improvement of that property. Substantial compliance with the requirement of investment in construction of a residential house satisfies the statutory condition.

Conclusion: Deduction under section 54F was allowable and the disallowance of the capital gain exemption was unsustainable.

Issues: (i) Whether the reassessment order was vitiated for non-disposal of the assessee's objections to the reopening under sections 147 and 148; (ii) Whether amounts treated as deemed application under Explanation (1)(2) to section 11(1) were required to be disclosed in Schedule-I of ITR-7, and whether the addition made for non-disclosure was sustainable.

Issue (i): Whether the reassessment order was vitiated for non-disposal of the assessee's objections to the reopening under sections 147 and 148.

Analysis: The assessee had raised objections to the reopening at the assessment stage, and those objections were found to have been uploaded along with the appeal papers. The Assessing Officer did not consider or dispose of the objections before completing the assessment. Such failure deprived the assessee of a fair consideration of its challenge to reopening and offended the principles of natural justice.

Conclusion: The reassessment order was vitiated on this ground and the issue was decided in favour of the assessee.

Issue (ii): Whether amounts treated as deemed application under Explanation (1)(2) to section 11(1) were required to be disclosed in Schedule-I of ITR-7, and whether the addition made for non-disclosure was sustainable.

Analysis: On the scheme of ITR-7 and the relevant instruction for Schedule-I, disclosure was required for amounts accumulated or set apart under section 11(2). The provision did not extend to deemed application under Explanation (1)(2) to section 11(1). The addition was therefore based on an erroneous reading of the return form requirements.

Conclusion: The deemed application amount was not required to be shown in Schedule-I, and the addition made on that basis was unsustainable. The issue was decided in favour of the assessee.

Final Conclusion: The assessment addition was deleted and the appeal was allowed in full.

Ratio Decidendi: Schedule-I of ITR-7 is confined to disclosure of amounts accumulated or set apart under section 11(2), and non-disposal of objections to reopening before completion of assessment renders the reassessment unsustainable as contrary to natural justice.