Issues: (i) Whether the Delhi and Haryana FIRs arising from the Brahma City/Krrish World transactions should be consolidated for a single investigation; (ii) Whether a blanket restraint against coercive action in respect of future FIRs based on the same transactions should be granted.

Issue (i): Whether the Delhi and Haryana FIRs arising from the Brahma City/Krrish World transactions should be consolidated for a single investigation.

Analysis: The FIRs disclosed a common thread of allegations concerning acceptance of money from homebuyers, failure to deliver promised properties, and related alleged diversion of funds. The prohibition on a second FIR in respect of the same occurrence or transaction requires a single comprehensive investigation; further material may be addressed through further investigation and supplementary reports rather than overlapping investigations in separate jurisdictions. Parallel investigations would cause multiplicity, potential conflicting findings, and prejudice to the petitioners. The subsequent Haryana FIR was found to arise from the same transaction as the Delhi EOW FIR.

Conclusion: FIR No. 30/2019 registered at the Economic Offences Wing, Delhi shall be transferred and clubbed with FIR No. 439/2024 registered at Police Station Sector-65, Gurugram, Haryana for investigation in accordance with law. This issue is in favour of the petitioners.

Issue (ii): Whether a blanket restraint against coercive action in respect of future FIRs based on the same transactions should be granted.

Analysis: A general prospective restraint against coercive action concerning FIRs that may be registered in future is neither appropriate nor legally permissible. The petitioners may pursue remedies available in law if any such FIR is registered.

Conclusion: The request for a blanket prospective restraint against coercive action is declined. This issue is against the petitioners.

Final Conclusion: The same-transaction allegations are required to be investigated in one coordinated proceeding, while future complaints remain subject to ordinary legal remedies.

Ratio Decidendi: Multiple FIRs and parallel investigations cannot be maintained for the same occurrence or transaction; subsequent information must be dealt with through a comprehensive investigation and, where necessary, further investigation or supplementary reports.

Issues: (i) Whether deletion of the addition for unexplained investment was justified; (ii) Whether deletion of the addition for unsecured loans treated as unexplained cash credits was justified.

Issue (i): Whether deletion of the addition for unexplained investment was justified.

Analysis: The additional evidence concerning the share investment, including the timing of payments, allotment of shares and bank records, was admitted and verified in remand proceedings. The remand report accepted that the investment was attributable to the assessee's own funds, which remained substantial notwithstanding losses.

Conclusion: Deletion of the addition for unexplained investment was justified, in favour of the assessee.

Issue (ii): Whether deletion of the addition for unsecured loans treated as unexplained cash credits was justified.

Analysis: Documentary material comprising creditors' ledger accounts, income-tax returns, bank records and financial statements was verified in remand proceedings. The accepted material established the identity and creditworthiness of the creditors and the genuineness of the loan transactions.

Conclusion: Deletion of the addition for unexplained cash credits was justified, in favour of the assessee.

Final Conclusion: The deletions of both additions are sustained because the remand verification accepted the evidentiary explanation for the investment and unsecured loans.

Ratio Decidendi: Where additional evidence is admitted, verified on remand and accepted as establishing the source of investment or the identity, creditworthiness and genuineness of creditors, the corresponding addition cannot be sustained.

Issues: Whether 67% service tax abatement under Notification No. 1/2006-S.T. dated 1st March 2006 is available where CENVAT credit initially availed was subsequently reversed with applicable interest.

Analysis: The notification excludes abatement where CENVAT credit on inputs, capital goods, or input services has been taken. The entire credit availed was subsequently reversed and interest for the delayed reversal was paid. There was no dispute regarding such reversal and payment of interest. Full reversal of the credit with applicable interest removes the bar to the abatement benefit.

Conclusion: The assessee is entitled to 67% abatement and is liable to service tax only on 33% of the gross value.

Issues: Whether the Commissioner of Income-tax (Exemptions) may impose contingent conditions on registration under section 12AB and approval under section 80G, making their tax benefits subject to the outcome of proposed higher-court litigation.

Analysis: Section 12AB does not confer an express power to impose independent conditions while granting registration. Rule 17A and Form No. 10AC cannot enlarge the substantive statutory power. Cancellation or withdrawal is governed separately by sections 12AB(4) and 12AB(5), which provide statutory safeguards for specified violations or non-genuine activities. The jurisdictional High Court decision concerning irrevocability of charitable trusts remained binding, and a proposed challenge before the Supreme Court could not justify keeping the benefits of already granted registration and approval in a contingent state.

Conclusion: The conditional stipulations attached to the registration under section 12AB and approval under section 80G were beyond jurisdiction and were directed to be deleted/vacated, in favour of the assessee.

Issues: (i) whether the suspension of mining operations could stand when it was issued without hearing, on an erroneous premise regarding environmental clearance, and without demonstrated jurisdictional facts; (ii) whether the petitioners were entitled to compensatory addition of the suspended period to the lease term; and (iii) whether delay, laches, or Section 8A of the Mines & Minerals (Development & Regulation) Act, 1957 barred the relief.

Issue (i): whether the suspension of mining operations could stand when it was issued without hearing, on an erroneous premise regarding environmental clearance, and without demonstrated jurisdictional facts.

Analysis: The leasehold interest was treated as protected property under Article 300A of the Constitution of India. The suspension order was found to rest on an incorrect assumption that there was no valid environmental clearance, although the clearance was held to be subsisting. The order was also held to have been passed without notice or opportunity of hearing, and the authority invoking the 2007 Rules was held not to have shown the necessary jurisdictional facts for exercise of power. The action was therefore treated as legally unsustainable and void ab initio.

Conclusion: The suspension order could not be sustained and was liable to be ignored for the purpose of granting consequential relief in favour of the petitioners.

Issue (ii): whether the petitioners were entitled to compensatory addition of the suspended period to the lease term.

Analysis: The lease deed and its force majeure arrangement were construed as permitting addition of the period during which the lessee was prevented from enjoying the leasehold because of wrongful State action. The Court held that the stoppage of mining constituted substantial interference with the right of quiet enjoyment, and that once resumption was permitted, denial of the lost period would defeat the contractual and equitable basis of relief. The distinction between grant or renewal of lease and compensatory restoration of the lost period was emphasised, and Section 8A of the Mines & Minerals (Development & Regulation) Act, 1957 was held not to bar such relief.

Conclusion: The petitioners were entitled to addition of the suspended period of 5 years and 10 months to the mining lease.

Issue (iii): whether delay, laches, or Section 8A of the Mines & Minerals (Development & Regulation) Act, 1957 barred the relief.

Analysis: The Court held that the petition was not defeated by delay and laches because the grievance had been pursued through representations and proceedings culminating in resumption, and because the impugned action affected substantive property rights under Article 300A. It further held that Section 8A did not prevent compensatory addition of the lost period, since the relief was not a fresh extension of lease but restoration of the period lost due to wrongful interdiction.

Conclusion: Neither delay and laches nor Section 8A barred the grant of relief.

Final Conclusion: The petition succeeded, and the petitioners were granted a mandamus for an additional operating period equal to the time lost during wrongful suspension, subject to ordinary compliances.

Ratio Decidendi: Where a statutory mining lease is wrongfully interrupted by an unsustainable State action passed without jurisdictional basis and without hearing, the lost period may be restored as compensatory relief, and such restoration is not barred merely because the lease is otherwise governed by a statutory outer limit on renewal or extension.

Issues: Whether the addition made under section 68 on the basis of the difference between the tax audit report figures and loan confirmation accounts, and the alleged failure to prove creditworthiness and genuineness of five lenders, was sustainable.

Analysis: The tax audit report reflected fresh loans received during the year, whereas the confirmation accounts were running accounts that also included repayments and reversal entries. The impugned comparison between cumulative credits and loan figures was therefore misconceived. The assessee produced confirmations, PAN, income-tax returns, audited financial statements and bank statements, and the Revenue did not bring rebuttal evidence to show that the credits were the assessee's own unaccounted money. The provision under section 68 required explanation of the credit, and an ad hoc addition of 20% of a supposed discrepancy had no statutory basis. The surrounding circumstances and banking trail did not displace the direct documentary evidence, and the selective acceptance of part of the credits while rejecting the balance was unsustainable.

Conclusion: The addition under section 68 was not justified and was deleted; the issue was decided in favour of the assessee.

Final Conclusion: The assessee's burden under section 68 was held to be discharged, and the sustained addition was set aside.

Ratio Decidendi: An addition under section 68 cannot rest on a comparison of non-comparable running-account entries with fresh loan figures, and once the assessee produces credible documentary evidence of identity, creditworthiness and genuineness, a purely ad hoc or suspicion-based addition is impermissible.

Issues: Whether the assessment for the search-related year of a non-searched person could be framed under section 143(3) instead of section 153C read with section 153A, and whether the assessment order was void for want of jurisdiction.

Analysis: The Revenue's challenge turned on the applicability of the first proviso to section 153C and the settled position that, in the case of a non-searched person, the relevant starting point for computing the block period is the date on which seized material is received by the jurisdictional Assessing Officer, not the date of search in the case of the searched person. Binding judicial precedent had already authoritatively settled this legal position, and the facts of the present case were found to be materially identical. In that view, the assessment ought to have been framed under section 153C read with section 153A, and the invocation of section 143(3) was held to suffer from a fatal jurisdictional defect.

Conclusion: The assessment framed under section 143(3) was held to be without jurisdiction and was not sustained; the Revenue's appeal was dismissed.

Final Conclusion: The order of the first appellate authority was upheld on the jurisdictional issue, resulting in the annulment of the assessment and no surviving relief in the assessee's cross-objection.

Ratio Decidendi: For a non-searched person, the six-year block under section 153C is reckoned from the date the seized material is received by the jurisdictional Assessing Officer, and an assessment made under section 143(3) in such a case is void for want of jurisdiction.

Issues: Whether the assessment framed under section 153C of the Income-tax Act, 1961 was vitiated for want of a timely and valid satisfaction note, and whether the consequential penalty orders could survive once the assessment was held void.

Analysis: The assessment was founded on material found in the search of another person, and the record showed a substantial delay in recording the satisfaction note after completion of the searched person's assessment. The legal position governing section 158BD, as applied to section 153C, requires a satisfaction note to be recorded at the statutorily permissible stage, i.e. contemporaneous with the search assessment, during those proceedings, or immediately after their completion. On the facts, the delay exceeded the permissible timeframe recognised in binding precedent and CBDT instructions, so the jurisdiction assumed for the section 153C assessment was invalid. Once the assessment itself failed, the penalty orders based on that assessment could not be independently sustained.

Conclusion: The assessment under section 153C was invalid for want of a timely satisfaction note, and the consequential penalty orders were also unsustainable.

Issues: Whether belated filing of Form No. 67 disentitles the assessee from claiming Foreign Tax Credit under section 90 of the Income-tax Act, 1961 read with the applicable DTAA.

Analysis: The Tribunal followed its coordinate bench view that Rule 128(9) of the Income-tax Rules, 1962 prescribes the manner and timing of filing Form No. 67 but does not provide for disallowance of Foreign Tax Credit merely because the form was filed after the due date under section 139(1) of the Income-tax Act, 1961. It held that the requirement is procedural and directory, not mandatory, and that the treaty-based entitlement to credit cannot be defeated by a procedural lapse. The Tribunal also held that the DTAA prevails to the extent it is beneficial to the assessee and that the claim could not be rejected on the sole ground of delayed filing of Form No. 67.

Conclusion: Belated filing of Form No. 67 did not justify denial of Foreign Tax Credit, and the assessee's claim was accepted.

Issues: Whether the demand raised under section 200A of the Income-tax Act, 1961 for alleged short deduction of tax on purchase of immovable property could be sustained when the seller's PAN had been regularised by Aadhaar linkage within the period covered by CBDT Circular No. 9/2025 and the seller had filed return of income and paid taxes, so that section 206AA and the deeming of default under section 201(1) would not apply.

Analysis: The assessee deducted tax at source under section 194IA on the consideration attributable to her 15% share in the property and deposited the tax through Form 26QB. The demand was founded only on the allegation that the seller's PAN was inoperative, attracting higher deduction under section 206AA. The material showed that the seller later linked Aadhaar with PAN and the PAN was regularised within the time contemplated by CBDT Circular No. 9/2025 dated 21.07.2025, which grants relief from higher-rate deduction for the relevant transactions. The seller had also filed the return of income for the relevant assessment year and paid tax on the capital gains, and thus the assessee could not be treated as an assessee-in-default under the proviso to section 201(1).

Conclusion: The demand under section 200A towards alleged short deduction, interest and levy was unsustainable and was directed to be deleted.

Final Conclusion: The appeal succeeded and the impugned demand was set aside in full.

Ratio Decidendi: Where the deductee's PAN is regularised within the period covered by the CBDT's operative clarification and the deductee has discharged tax liability, higher-rate deduction under section 206AA cannot be enforced and a consequential demand under section 200A cannot survive; the deductor is not to be treated as an assessee-in-default under section 201(1).

Issues: Whether amounts received by a claimant under a Mediclaim or medical insurance policy are deductible from compensation awarded by the Motor Accidents Claims Tribunal under the Motor Vehicles Act, 1988, including under the head of medical expenses.

Analysis: The governing principle in motor accident compensation is to award just compensation without duplication for the same head of loss. Deductions are ordinarily justified only where the receipt has the same source and nature as the loss compensated, or where it is a substitute for the very loss arising from the accident. By contrast, Mediclaim is a contractual benefit purchased by payment of premiums and does not arise from the accident itself. Compensation under the Motor Vehicles Act is a statutory entitlement triggered by the accident, whereas reimbursement under a Mediclaim policy flows from a separate contractual arrangement. Treating the two as overlapping would ignore the distinct source of the benefit and would unfairly deprive the claimant of the contractual advantage purchased in advance.

Conclusion: Mediclaim or medical insurance amounts are not deductible from compensation awarded under the Motor Vehicles Act, 1988, even when medical expenses are claimed before the Tribunal.

Outcome: Delay condoned. The petitions were disposed of in terms of the Court's earlier orders, and the matters were remitted to the High Court for decision accordingly.

Outcome: The petitions were disposed of in the same terms as the earlier orders and the matters were remitted to the High Court for decision accordingly.

Issues: (i) whether the demand of service tax under the category of Renting of Immovable Property Service was sustainable, and (ii) whether compensation received from Coca-Cola India for not meeting the guaranteed number of coolers was liable to service tax under the category of Testing Service.

Issue (i): whether the demand of service tax under the category of Renting of Immovable Property Service was sustainable.

Analysis: The demand on rental charges had already been accepted by the appellant before the adjudicating authority, and the adjudicating authority had extended the benefit of waiver of penalty. The appellate forum found no infirmity in the confirmation of service tax on the renting component and treated the classification objection as not open at that stage.

Conclusion: The demand of service tax under the category of Renting of Immovable Property Service was upheld.

Issue (ii): whether compensation received from Coca-Cola India for not meeting the guaranteed number of coolers was liable to service tax under the category of Testing Service.

Analysis: The amount was found to be in the nature of compensation or liquidated damages payable for failure to supply the agreed number of coolers, and not consideration for any service rendered by the appellant. The forum also held that inclusion of such amount in the taxable value by invoking Rule 5(1) of the Service Tax (Determination of Value) Rules, 2006 was not sustainable, as that provision could not justify tax on the impugned amount.

Conclusion: The demand of service tax on the compensation charges was set aside.

Final Conclusion: The appeal succeeded only in respect of the compensation component, while the service tax demand on renting charges was sustained.

Ratio Decidendi: Amounts paid as liquidated damages or compensation for breach or non-fulfilment of contractual obligations are not consideration for taxable services and cannot be included in taxable value by invoking Rule 5(1) of the Service Tax (Determination of Value) Rules, 2006.

Outcome: The appeal was disposed of as abated because the corporate debtor's resolution plan had been approved in insolvency proceedings, rendering the Tribunal functus officio in the matter.

Issues: Whether the first appellate authority could dismiss the appeal in limine for delay without adjudicating the merits, and whether the matter required remand for consideration of condonation of delay under the Income-tax Act, 1961.

Analysis: The appeal before the first appellate authority had been rejected solely on the ground that the delay in filing was not condoned, without examining the merits. The Tribunal noted the principle that an appellate authority is expected to dispose of the appeal in accordance with the statutory scheme and the principles of natural justice, and that where the explanation for delay has not been examined on a proper basis, a further opportunity can be granted to the appellant to explain the delay. In the interest of substantive justice, the Tribunal found it appropriate to restore the matter so that the delay question may be considered afresh, and, if condonation is granted, the appeal may then be decided on merits.

Conclusion: The order dismissing the appeal in limine was set aside and the matter was remanded to the first appellate authority for fresh consideration of condonation of delay and, if condoned, disposal on merits.

Issues: Whether the addition made under section 68 read with section 115BBE of the Income-tax Act, 1961 on account of cash deposits during the demonetisation period was justified, or whether the deposits were explained by cash sales and receipts from debtors.

Analysis: The assessee's books of account, trading results, cash book, stock position and sales records were accepted and were not rejected by the Assessing Officer. The appellate record showed that the cash deposits were supported by regular business receipts, including cash sales in a business where such cash generation was normal, and that no defect was found in the purchases, sales or stock records. The application of section 40A(3) was held to be misplaced because the assessee was not claiming deduction for cash expenditure but was explaining receipt-side cash inflows. On the facts, the addition under section 68 would amount to treating already recorded sales again as unexplained income.

Conclusion: The addition under section 68 read with section 115BBE was not sustainable and deletion of the addition was upheld.

Final Conclusion: The Revenue's challenge failed and the order deleting the addition was affirmed, resulting in dismissal of the appeal.

Ratio Decidendi: Where cash deposits are explained by duly recorded cash sales, supported by accepted books of account and unchallenged stock and trading results, an addition under section 68 cannot be sustained merely on suspicion or on the basis of section 40A(3).

Issues: Whether the assessee university was entitled to exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961, and whether the test of being "substantially financed by the Government" was to be applied on cumulative grants from inception or only on Government grants received during the relevant previous year.

Analysis: Section 10(23C)(iiiab), read with the Explanation and Rule 2BBB of the Income-tax Rules, 1962, requires that a university or other educational institution existing solely for educational purposes and not for profit must be wholly or substantially financed by the Government. The governing language makes the relevant test year-specific, because the prescribed percentage is to be applied to Government grants received during the relevant previous year against total receipts, including voluntary contributions. The cumulative grant theory was rejected as inconsistent with the text and legislative scheme. On the facts, the assessee received Government grants of 47.85% for assessment year 2016-17 and 9.77% for assessment year 2017-18, both below the statutory threshold of 50%.

Conclusion: The assessee was not entitled to exemption under section 10(23C)(iiiab), and the denial of exemption was / upheld against the assessee.

Final Conclusion: The appeals failed, as the assessee did not satisfy the statutory requirement of substantial Government financing for the relevant previous years.

Ratio Decidendi: For exemption under section 10(23C)(iiiab), the extent of Government financing must be determined with reference to the relevant previous year, and only if Government grants exceed 50% of total receipts can the institution be treated as substantially financed by the Government.

Issues: Whether addition to capital gains could be sustained under section 50C of the Income-tax Act, 1961, when the assessee's registered valuer determined the property's fair market value to be lower than the declared sale consideration and the property was affected by restrictive land-use conditions.

Analysis: The property was shown to be situated within a restricted area near defence land, subject to no-development constraints, reduced accessibility, and other locational disadvantages. The Government Registered Valuer's report, which considered these factors along with the surrounding circumstances and comparable local evidence, valued the property below the sale consideration declared by the assessee. In these circumstances, the higher valuation adopted by the DVO was not accepted as the correct basis for substitution of the declared consideration, and the factual foundation for invoking section 50C was found wanting.

Conclusion: The addition made by the Assessing Officer and sustained by the first appellate authority was deleted, and the declared capital gain was accepted.

Final Conclusion: The assessee succeeded on merits, and the impugned addition based on substituted valuation was set aside.

Ratio Decidendi: Where reliable valuation evidence establishes that the fair market value of an immovable property is below the declared sale consideration, and the property is burdened by material restrictive conditions affecting marketability, substitution of consideration under section 50C is not warranted.

Issues: Whether the compensation received under the voluntary retirement scheme was taxable as profits in lieu of salary under section 17(3)(i) of the Income-tax Act, 1961, or was a capital receipt not chargeable to tax.

Analysis: The compensation was received on cessation of employment under a voluntary retirement arrangement. The deciding consideration was whether the payment was in the nature of compensation connected with termination of employment so as to fall within section 17(3)(i), or whether it was a voluntary ex gratia payment arising from loss of employment and therefore outside the scope of that provision. Following the coordinate bench decisions relied upon, and the principle that a purely voluntary payment without a corresponding legal obligation on the employer does not constitute taxable compensation in lieu of salary, the addition could not be sustained.

Conclusion: The compensation received under the voluntary retirement scheme was held not taxable under section 17(3)(i) and was to be treated as a capital receipt. The addition was directed to be deleted, in favour of the assessee.

Final Conclusion: The appeal succeeded and the impugned addition was deleted, with consequential relief granted to the assessee.

Ratio Decidendi: A voluntary ex gratia payment received on cessation of employment, without any enforceable obligation on the employer to make such payment, does not amount to compensation within section 17(3)(i) of the Income-tax Act, 1961.