Issues: Whether disallowance under section 14A read with Rule 8D could be sustained when no exempt income was earned during the year, and whether the Explanation to section 14A could be applied retrospectively.

Analysis: The assessee had not earned any exempt income in the relevant assessment year. On those facts, disallowance under section 14A read with Rule 8D was held to be impermissible. The Explanation to section 14A was also treated as prospective in operation and not retrospective, so it could not enlarge the disallowance for the year under consideration. The Revenue's reliance on cited authorities was found distinguishable on facts, and the view already taken in identical matters was followed for consistency.

Conclusion: The disallowance under section 14A read with Rule 8D was not justified, and the deletion made by the appellate authority was upheld.

Issues: Whether the assessments framed under section 153C read with section 143(3) of the Income-tax Act, 1961 were valid in the absence of proper satisfaction recording that the seized material pertained to or related to the assessees.

Analysis: The search was conducted in the case of a third party group, and the Assessing Officers recorded satisfaction to proceed against the assessees under section 153C. The governing post-amendment legal position requires the seized material to be shown as pertaining to or relating to the third party assessee, and the recording of proper satisfaction is a condition precedent for assumption of jurisdiction. Applying the earlier tribunal view on the same issue, the Tribunal found no basis to sustain the impugned assessments.

Conclusion: The assessments under section 153C read with section 143(3) were quashed for want of proper satisfaction, in favour of the assessees.

Ratio Decidendi: For proceedings under section 153C of the Income-tax Act, 1961, proper satisfaction that the seized material pertains to or relates to the third party assessee is a jurisdictional condition precedent, and failure to record such satisfaction invalidates the assessment.

Issues: (i) Whether the cash deposit of Rs. 20,00,000 was liable to be treated as unexplained money under section 69A when it was claimed to be a re-deposit of earlier withdrawals from the same bank account; (ii) Whether the amount received from LIC towards office maintenance and transaction fee was taxable income or only reimbursement of expenses.

Issue (i): Whether the cash deposit of Rs. 20,00,000 was liable to be treated as unexplained money under section 69A when it was claimed to be a re-deposit of earlier withdrawals from the same bank account.

Analysis: The bank statement showed cash withdrawals aggregating to Rs. 28,40,000 before the impugned deposit, and the assessment record itself noted those withdrawals. The source of the deposit was therefore traceable to the assessee's own funds withdrawn from the same bank account, and no material was brought to show that the withdrawn cash had been utilized elsewhere. The factual finding of the first appellate authority that no bank statement had been produced was held to be contrary to the record.

Conclusion: The addition under section 69A was unsustainable and was deleted in favour of the assessee.

Issue (ii): Whether the amount received from LIC towards office maintenance and transaction fee was taxable income or only reimbursement of expenses.

Analysis: The LIC letter and the material on record showed that the assessee had been paid Rs. 2,20,000 towards office maintenance and Rs. 80,290 towards transaction fee. These payments were treated as reimbursements for expenses incurred in the course of official duties, and therefore did not constitute taxable income to that extent. The adverse finding of the first appellate authority was held to be unsustainable.

Conclusion: The disallowance of Rs. 3,00,290 was set aside and relief was granted to the assessee to that extent.

Final Conclusion: The appeal succeeded in part, with relief granted on both substantive additions and the impugned appellate order set aside.

Ratio Decidendi: A cash deposit is not assessable as unexplained money where prior withdrawals from the same account reasonably explain the redeposit and the revenue does not show alternative utilization of the withdrawn cash; similarly, amounts proved to be reimbursement of actual expenses do not assume the character of taxable income.

Issues: (i) Whether the delay of 850 days in filing the appeal before the first appellate authority deserved condonation. (ii) Whether penalty under section 271(1)(c) was leviable on the assessee for the disallowance linked to deduction under section 80IB(10).

Issue (i): Whether the delay of 850 days in filing the appeal before the first appellate authority deserved condonation.

Analysis: The delay was explained on the ground that the penalty order had remained with an accountant who later left without informing the partners, and the assessee claimed to have learnt of the order only when recovery steps commenced. The record showed that the related quantum issue had travelled through appellate stages and was pending before the Supreme Court. In these circumstances, the assessee's failure to prosecute the first appeal could not be treated as mala fide, and the delay was viewed as deserving a liberal approach in the interest of substantial justice.

Conclusion: The delay was condoned.

Issue (ii): Whether penalty under section 271(1)(c) was leviable on the assessee for the disallowance linked to deduction under section 80IB(10).

Analysis: The penalty arose from disallowance of deduction under section 80IB(10), an issue on which different judicial authorities had taken divergent views in the assessee's own case for an earlier assessment year. The existence of conflicting views showed that the matter was debatable. A claim that is unsustainable on one view of law does not by itself amount to concealment of income or furnishing of inaccurate particulars when the assessee has adopted one of the possible views. On that basis, the essential ingredients for penalty were not established.

Conclusion: Penalty under section 271(1)(c) was not leviable and was directed to be deleted.

Final Conclusion: The assessee succeeded on both the delay issue and the penalty issue, and the penalty demand was set aside.

Ratio Decidendi: Penalty under section 271(1)(c) cannot be sustained where the addition rests on a debatable issue and the assessee has taken one of two possible views without concealment or furnishing of inaccurate particulars.

Issues: Whether the portion of research and development expenditure not approved for weighted deduction under section 35(2AB) of the Income-tax Act, 1961 could nevertheless be allowed as a normal business expenditure under section 37(1) of the Act.

Analysis: The expenditure was incurred on salary, material consumption and other items for in-house research and development. The prescribed authority certified only part of the expenditure in Form 3CL for weighted deduction under section 35(2AB), and the balance was therefore not eligible for the enhanced deduction. However, the genuineness of the underlying expenditure was not doubted, and the mere fact that a part of the claim did not qualify for weighted deduction did not, by itself, make the amount non-deductible as business expenditure.

Conclusion: The disallowance of weighted deduction for the uncertified portion was upheld, but the balance amount was directed to be allowed under section 37(1) of the Income-tax Act, 1961.

Final Conclusion: The appeal succeeded only to the extent that the disallowed research and development expenditure was held deductible as normal business expenditure, while the denial of weighted deduction remained intact.

Ratio Decidendi: Expenditure incurred for business purposes does not cease to be deductible under section 37(1) merely because it is not certified for weighted deduction under section 35(2AB), where its genuineness is not in dispute.

Issues: Whether the reassessment was liable to be quashed for failure to establish valid issuance and service of notice under section 143(2) of the Income-tax Act, 1961, thereby rendering the assessment void ab initio.

Analysis: The reassessment record did not contain the notice itself, and the Assessing Officer's RTI reply stated that the contents of the alleged notice under section 143(2) were not available in the system and a copy could not be furnished. The departmental record also showed ambiguity as to whether the entry related to notice under section 143(2) or notice under section 148. In these circumstances, the foundational jurisdictional requirement of a valid notice under section 143(2) was held to remain unproved. Since such notice is mandatory for a valid reassessment, the defect was treated as going to the root of jurisdiction and not as a mere technical irregularity.

Conclusion: The reassessment was invalid for want of proved issuance and service of notice under section 143(2), and the assessment was quashed in favour of the assessee.

Final Conclusion: The appeal succeeded and the reassessment could not be sustained because the Revenue failed to establish the mandatory jurisdictional notice.

Ratio Decidendi: A reassessment cannot be sustained unless the Revenue proves valid issuance and service of the mandatory notice under section 143(2); where that foundational requirement is unproved, the assessment is void for want of jurisdiction.

Issues: Whether cash deposits made during the demonetisation period could be assessed as unexplained cash credits under section 68 and subjected to section 115BBE when the assessee claimed the deposits were out of recorded cash sales and bank withdrawals.

Analysis: The assessee produced cash book, stock details, purchase and sales records, and other supporting material showing that the cash deposits were made from recorded business receipts and available cash balance. The turnover, trading results, and stock position were not doubted by the lower authorities, and no adverse material or specific defect in the books of account was brought on record. On these facts, the addition would amount to taxing the same receipts twice, once as sales income and again as the bank deposit, which is impermissible. In the absence of rebuttal of the documentary evidence, invocation of section 68 and consequential section 115BBE was not justified.

Conclusion: The addition on account of cash deposits was deleted and the issue was decided in favour of the assessee.

Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961 and the consequent reassessment proceedings were valid when the assessee's returned income fell within the monetary limit for allocation to the Income-tax Officer under CBDT Instruction No. 1/2011.

Analysis: The assessee had declared income below the monetary threshold prescribed for non-corporate returns in metro cities. On the facts recorded, the relevant CBDT instruction required such cases to be handled by the Income-tax Officer and not by the Assistant Commissioner of Income Tax. Since the notice under section 148 was issued by an without the prescribed jurisdiction, the defect went to the root of the assumption of jurisdiction. The reassessment proceedings founded on that notice could not survive.

Conclusion: The notice under section 148 was without jurisdiction and void ab initio, and the reassessment proceedings were quashed in favour of the assessee.

Final Conclusion: The appeal succeeded because the reassessment was annulled for want of jurisdiction in issuing the notice.

Ratio Decidendi: Where a CBDT instruction validly assigns cases on the basis of monetary limits, a reassessment notice issued by an outside the prescribed allocation is without jurisdiction and the proceedings based on it are vitiated.

Issues: Whether the export incentive received under the Focus Product Scheme was to be treated as a capital receipt and allowed as such in assessment.

Analysis: The assessee raised the claim during assessment proceedings by way of a letter and the appellate authority ought to have examined it on merits. The issue was found to be covered by the coordinate bench decision in the immediately succeeding assessment year on identical facts. Following that view, the incentive under the Focus Product Scheme was held to be an export incentive directed towards market expansion and therefore a capital receipt, not assessable as income.

Conclusion: The claim was accepted and the incentive under the Focus Product Scheme was held to be a capital receipt, in favour of the assessee.

Issues: Whether reassessment proceedings initiated by notice issued in the name of a deceased person were without jurisdiction and liable to be quashed.

Analysis: The assessee had expired before issuance of notice under section 148A(b) and notice under section 148. The issuance of notice to a deceased person was a foundational jurisdictional defect because a valid notice under section 148 is necessary for assumption of jurisdiction under section 147. Section 159 permits continuation of validly initiated proceedings against a legal representative, but it does not authorise initiation against a non-existent person. Since no fresh notice was issued in the name of the legal representative, the defect was not cured. The case was distinguishable from situations where valid proceedings had commenced during the lifetime of the assessee. The defect was substantive and not a mere procedural irregularity.

Conclusion: The reassessment proceedings were void ab initio and the quashing of the assessment was in law; the Revenue's challenge failed.

Ratio Decidendi: A reassessment initiated by notice issued in the name of a deceased person is void for want of jurisdiction, and such defect cannot be cured by later impleadment or continuation against the legal representative unless valid proceedings had already commenced during the assessee's lifetime.

Issues: Whether the petitioner should be permitted to re-export the goods and whether the authorities should be directed to grant all necessary permissions to facilitate such re-export.

Analysis: The Court granted the request only as an indulgence, taking note of the petitioner's stated position that the goods would be re-exported by the adjourned date. It directed the authorities to permit re-export as already applied for and to grant all necessary permissions to facilitate the same. The Court further noted the earlier request for extension of time and observed that, if re-export was not possible by the adjourned date, there would be a ground for rejection of the petition.

Conclusion: The petitioner was permitted to re-export the goods and the authorities were directed to grant the necessary permissions, but the matter was only adjourned and not finally concluded.

Issues: Whether the petitioner was entitled to directions for revocation of cancellation of GST registration and restoration of registration subject to compliance with tax and return filing requirements.

Analysis: The writ petition challenged cancellation of registration on the ground of non-filing of returns and non-payment of taxes. The Court disposed of the matter by issuing compliance-oriented directions requiring the petitioner to seek revocation, file draft returns, and deposit all taxes due. The registering authority was directed to receive payment before considering revocation, decide the application within a fixed time, and restore registration if the application was accepted. The Court also permitted manual filing if online filing caused difficulty.

Conclusion: The petitioner was granted conditional relief enabling consideration of revocation and possible restoration of GST registration, subject to compliance with the stipulated requirements.

Issues: Whether deduction under section 54 of the Income-tax Act, 1961 was allowable where the assessee did not deposit the unutilised capital gains in the capital gains account scheme before the due date under section 139(1), but claimed to have invested the sale consideration in the new residential property before filing the return under section 139.

Analysis: Section 54(1) grants exemption where the capital gain is invested in purchase or construction of a new residential house within the prescribed period, while section 54(2) requires only the unutilised amount to be deposited in the notified account before furnishing the return, not later than the due date under section 139(1). The decisive question was whether the assessee had already utilised the capital gain for purchase of the new property before filing the return. The jurisdictional precedent relied upon by the Revenue was distinguished on the footing that it addressed a case of unutilised capital gains not deposited within time, whereas the present facts were treated as falling within the line of authority recognising that actual utilisation before the return date can satisfy the statutory scheme. Since the record before the Tribunal did not fully verify the payment details for the new property, the claim could not be finally concluded without that factual verification.

Conclusion: The assessee was held entitled in principle to deduction under section 54 if the capital gains had been utilised for purchase of the new property before filing the return, and the matter was remanded to the Assessing Officer for limited verification of the payments and consequential allowance.

Final Conclusion: The appeal succeeded to the extent that the deduction claim was accepted in principle, but the grant of relief depended upon verification of the payment record by the Assessing Officer.

Ratio Decidendi: Where the capital gains are actually utilised for purchase of a new residential house before filing the return, the exemption under section 54 cannot be denied merely for non-deposit in the capital gains account scheme, though the factual utilisation must be verified.

Issues: Whether deduction under section 80P could be denied by way of prima facie adjustment under section 143(1) on the ground that the return was filed beyond the due date under section 139(1) for assessment year 2015-16, and whether the amended section 80AC applied retrospectively to bar the claim.

Analysis: The Tribunal noted that the controversy stood covered by earlier coordinate bench decisions holding that the amendment to section 80AC, which extended the due-date filing condition to deductions under Chapter VI-A including section 80P, operated only prospectively from assessment year 2018-19. It further held that, for the relevant year, there was no enabling provision permitting disallowance of section 80P deduction at the processing stage merely because the return was filed late, since the issue was debatable and lay outside the limited scope of adjustments under section 143(1).

Conclusion: The denial of deduction under section 80P through processing under section 143(1) was unsustainable, and the assessee was entitled to the deduction claimed.

Ratio Decidendi: An amendment enlarging the due-date filing condition for Chapter VI-A deductions is prospective where so held, and a debatable claim for section 80P deduction cannot be disallowed as a prima facie adjustment under section 143(1) for an earlier assessment year.

Issues: (i) Whether the provisional attachment could be sustained even though the appellant was not named as an accused in the FIRs or charge sheets. (ii) Whether the material on record established that the appellant's NBFC licence and related funds were used in a lending model generating proceeds of crime and justifying attachment under the PMLA.

Issue (i): Whether the provisional attachment could be sustained even though the appellant was not named as an accused in the FIRs or charge sheets.

Analysis: The attachment power under Section 5 of the Prevention of Money Laundering Act, 2002 is not confined to property held by a person named as an accused in the scheduled offence. The decisive consideration is whether the person is in possession of proceeds of crime and whether the authorised officer has reason to believe, on the basis of material in possession, that such property is liable to be concealed, transferred or otherwise dealt with so as to frustrate confiscation. The absence of the appellant's name in the predicate FIRs did not, by itself, defeat attachment where the investigation disclosed its linkage with the lending operations and the funds under scrutiny.

Conclusion: The issue was answered against the appellant and in favour of the respondent.

Issue (ii): Whether the material on record established that the appellant's NBFC licence and related funds were used in a lending model generating proceeds of crime and justifying attachment under the PMLA.

Analysis: The record disclosed a digital lending model in which fintech entities and the appellant operated through mobile applications, collected borrower data, advanced short-term loans, deducted substantial amounts upfront as processing or platform charges, and used coercive recovery methods. The Tribunal relied on the agreements and surrounding material to hold that core lending functions had effectively been outsourced in a manner inconsistent with RBI norms, while the appellant's licence facilitated the business model. The rise in loan volume and revenue, the use of fintech deposits as performance guarantees, and the alleged exploitation of borrowers supported the conclusion that the appellant had facilitated and benefited from activities generating proceeds of crime.

Conclusion: The issue was answered against the appellant and in favour of the respondent.

Final Conclusion: The appeal was rejected, and the provisional attachment was upheld on the basis that the appellant's participation in the lending structure brought the attached assets within the ambit of proceeds of crime under the PMLA.

Ratio Decidendi: For the purpose of provisional attachment under the PMLA, property may be attached from any person in possession of proceeds of crime, and the statute is not limited to property held by a person formally arraigned as an accused in the scheduled offence.

Issues: Whether an ex parte GST assessment order, passed without effective participation of the assessee, should be set aside and remanded to enable the assessee to file reply and supporting documents.

Analysis: The assessment was made ex parte because the assessee did not avail the opportunities provided. The Court took note of the explanation regarding the alleged input tax credit mismatch, ineligible input tax credit, late filing of return, and the levy of penalty and interest. Considering the nature of the discrepancies and the explanation offered for non-participation, the Court held that the assessee should be afforded an opportunity to place materials before the assessing officer. The Court also noted that, although such relief is ordinarily conditioned on deposit of 25% of the disputed tax, 35% of the demand had already been recovered and no further condition was warranted.

Conclusion: The ex parte assessment order was set aside and the matter was remanded for fresh adjudication after giving the assessee an opportunity to submit reply and documents. The bank account attachment passed pursuant to the assessment was also raised.

Ratio Decidendi: Where an assessment is rendered ex parte and the assessee shows sufficient cause for non-participation, the order may be set aside and remanded to secure a fair opportunity of hearing before fresh adjudication.

Issues: Whether penalties imposed on the freight forwarder and its authorised representative under Sections 114 and 114AA of the Customs Act, 1962 were sustainable on the facts found.

Analysis: The factual foundation for the penalties was found to rest on assumptions rather than a logical appraisal of the evidence. The movement of the goods in containers without RFID e-seal, in the circumstances of the case, could not by itself constitute an offence, particularly when the exporter did not have self-sealing permission and the goods were in fact subjected to examination under the prescribed RMS procedure. The reasoning in the impugned order did not establish any concrete nexus between the appellants and the alleged fake or dummy documents, nor did it identify any export benefit that accrued to them. The setting aside of penalties on the co-noticees, who were said to have generated the alleged dummy documents, further weakened the basis for sustaining penalties against the present appellants.

Conclusion: The penalties under Sections 114 and 114AA of the Customs Act, 1962 were not sustainable against the appellants.

Ratio Decidendi: A penalty for attempted improper export or for use of false documents cannot be sustained unless the department establishes a clear nexus, knowledge, and culpable participation of the person proceeded against; mere irregular handling of cargo or reliance on assumptions is insufficient.

Issues: Whether the miscellaneous application for rectification disclosed any mistake apparent on the record in the final order so as to justify rectification and recall.

Analysis: The application was founded on the allegation that certain submissions in the earlier order had not been separately discussed while deciding the same issue. The record showed, however, that the earlier order had already addressed the relevant factual process and had applied the governing law on manufacture, including the effect of Note 3 to Chapter 18 of the Central Excise Tariff Act, 1985 and the definition of manufacture under the Central Excise Act, 1944. Since the impugned order had followed the binding Supreme Court position on the issue and had adopted the same view, the alleged omission did not disclose any patent error requiring rectification. Non-discussion of each submission, where the issue itself stood decided on the basis of the applicable law, was not treated as a mistake apparent on the record.

Conclusion: No mistake apparent on the record was made out, and the rectification application was rightly rejected.

Ratio Decidendi: A rectification application cannot succeed merely because some submissions were not separately adverted to, where the underlying issue has already been decided in conformity with binding law and no patent error is shown on the face of the record.

Issues: (i) Whether the assessment order was vitiated for absence of a Document Identification Number or RFN number; (ii) Whether the writ petition could be entertained despite delay and what conditions should govern such interference, including service of the order through the portal.

Issue (i): Whether the assessment order was vitiated for absence of a Document Identification Number or RFN number.

Analysis: The assessment order was challenged on the ground that it did not bear a Document Identification Number or RFN number. The Court followed its earlier view that absence of a DIN renders such an order invalid and treated the defect as an inherent irregularity affecting the order itself.

Conclusion: The issue was answered in favour of the assessee.

Issue (ii): Whether the writ petition could be entertained despite delay and what conditions should govern such interference, including service of the order through the portal.

Analysis: The respondents relied on portal-based service and delay in approaching the Court. The Court noted the statutory method of service through the portal, but also considered the practical difficulties faced by registered persons under the GST regime and balanced that against revenue administration. In that context, it held that delayed writ petitions against orders suffering from patent irregularities could be considered subject to payment of a portion of the disputed tax, and directed remand after notice and hearing.

Conclusion: The issue was answered in favour of the assessee, subject to the condition of depositing 20% of the disputed tax.

Final Conclusion: The assessment order was set aside and the matter was remanded for fresh assessment after due opportunity of hearing, with the writ being entertained on the specified pre-deposit condition.

Ratio Decidendi: An assessment order suffering from absence of a mandatory identification number is liable to be invalidated, and delayed challenges to such patently irregular GST orders may be entertained on equitable terms including a limited pre-deposit and remand for fresh adjudication.

Issues: Whether the assessment order could be sustained when notice was served by upload on the portal and whether the assessee was entitled to a fresh opportunity before reassessment.

Analysis: Service through the portal was treated as valid service under Section 169(1)(d) of the G.S.T. Act, 2017. Even so, the matter called for a fair opportunity to the assessee in view of the practical difficulties arising from online service and the interests of justice. The appropriate course was to set aside the assessment and remit the matter for reconsideration after notice.

Conclusion: The writ petition was allowed, the assessment order was set aside, and the matter was remanded for fresh assessment after notice to the petitioner, subject to deposit of 20% of the disputed tax.