Issues: Whether the TDS credit on dividend income arising from the deceased's assets could be granted to the estate, and whether the first appellate authority could restore the matter to the Assessing Officer for verification.

Analysis: The estate was formed after the death of the individual and the return was filed in the capacity of an Association of Persons under section 168 of the Income-tax Act, 1961. Income accruing from the assets of the deceased after death is taxable in the hands of the estate through the executor, and corresponding TDS credit belongs to the person in whose hands such income is taxable. The record, however, did not clearly show whether the dividend income related wholly to the post-death period or partly to the pre-death period, making factual verification necessary. At the same time, the appellate authority's power under section 251 does not include remanding the matter to the Assessing Officer for fresh verification, except in cases covered by section 144.

Conclusion: The estate is entitled to TDS credit if the income is found to relate to the post-death period, and the matter must be verified by the Assessing Officer in accordance with law. The order restoring the issue to the Assessing Officer was not sustainable, but the need for verification was upheld, resulting in relief in part to the assessee.

Final Conclusion: The appeal succeeded to the extent that the assessee's claim for TDS credit remained open for allowance on verification, and the appellate order was modified in part while preserving the substantive entitlement issue.

Ratio Decidendi: Income arising after the death of an individual from estate assets is taxable in the hands of the estate, with TDS credit available accordingly, and the first appellate authority cannot remand the matter to the Assessing Officer except as permitted by the statute.

Issues: Whether the Revenue was justified in sustaining the addition made on account of alleged bogus purchases and related commission expenditure, and whether the assessee had established the genuineness of the purchases through documentary evidence.

Analysis: The addition was founded on information suggesting accommodation entries and on alleged deficiencies in the purchase evidence. The assessee, however, produced purchase and sales invoices, ledger accounts, bank statements, registers and other supporting material to discharge the initial onus. The assessment order did not show any meaningful rebuttal of those documents, nor any adequate independent enquiry, verification of the suppliers, or effective linkage between the alleged accommodation entry information and the assessee's purchases. The absence of concrete adverse findings against the documentary evidence led to the conclusion that the Revenue had not disproved the assessee's claim. The precedents relied upon by the Revenue were found distinguishable on facts.

Conclusion: The addition on account of alleged bogus purchases and commission expenditure was not sustained, and the assessee succeeded.

Issues: (i) Whether the addition made under section 69A on account of alleged unexplained excess gold jewellery was sustainable or required fresh verification; (ii) Whether the addition made towards difference in business income could be sustained on the basis of the survey declaration.

Issue (i): Whether the addition made under section 69A on account of alleged unexplained excess gold jewellery was sustainable or required fresh verification.

Analysis: The disputed excess gold jewellery was claimed to have been received from customers for job work and not owned by the assessee. Fresh details of receipt, return, quantity, and labour charges were produced, but those particulars had not been examined by the lower authorities. In view of the additional material and the requirement of fair opportunity, the matter needed verification by the Assessing Officer.

Conclusion: The issue was restored to the Assessing Officer for fresh adjudication and the relief was allowed for statistical purposes.

Issue (ii): Whether the addition made towards difference in business income could be sustained on the basis of the survey declaration.

Analysis: The addition was based only on the declaration recorded during survey, while the assessee's books were audited and the return disclosed the business income claimed to have actually been earned. On the facts placed, the survey declaration was not treated as sufficient to sustain the addition.

Conclusion: The addition towards difference in business income was directed to be deleted and the issue was decided in favour of the assessee.

Final Conclusion: The appeal succeeded only in part, with one issue remitted for reconsideration and the other resulting in deletion of the addition.

Ratio Decidendi: Where material evidence supporting a job-work explanation has not been examined, and the assessee is afforded no effective verification of such evidence, the addition cannot be finally sustained without fresh inquiry; a survey declaration alone does not automatically justify a business-income addition when the audited books and return are otherwise relied upon.

Issues: (i) Whether late fee under section 234E could be levied in an intimation under section 200A for TDS statements pertaining to a period before 01.06.2015, and whether the fee, if any, had to be recalculated only from 01.06.2015.

Analysis: The amendment to section 200A enabling computation of fee under section 234E was treated as prospective from 01.06.2015. On that basis, late fee could not be computed for the period prior to that date. For statements where the default continued beyond 01.06.2015, the fee was to be recomputed only for the period commencing from 01.06.2015 up to the date of filing or processing, as applicable.

Conclusion: The levy was not sustained for the pre-01.06.2015 period. The matter was set aside for fresh computation of fee, if any, only from 01.06.2015 onwards, and the appeals were partly allowed.

Issues: Whether compensation received on compulsory acquisition of agricultural land under the National Highways Act was exempt from tax and could not be assessed as income from other sources.

Analysis: The assessee received compensation together with statutory interest for acquisition of agricultural land for widening of a national highway. The compensation amount had been wrongly shown in the return as exempt agricultural income, but the record established that it was in fact compensation for compulsory acquisition. The Tribunal noted that the lower authorities had accepted the interest component as exempt and had taxed only the original compensation. It relied on the statutory exemption under section 10(37) of the Income-tax Act and on section 96 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, as clarified by CBDT Circular No. 36 of 2016. The Tribunal also took note of the legal position that the benefit of the later land acquisition regime extends to acquisitions under the National Highways Act, 1956.

Conclusion: The compensation received for compulsory acquisition of the land was not taxable as income from other sources and was entitled to exemption.

Issues: (i) Whether the cash deposit of Rs. 25,00,000 in HDFC Bank during the demonetization period was liable to be treated as unexplained investment under section 69. (ii) Whether the amount sustained could be subjected to tax under section 115BBE for Assessment Year 2017-18.

Issue (i): Whether the cash deposit of Rs. 25,00,000 in HDFC Bank during the demonetization period was liable to be treated as unexplained investment under section 69.

Analysis: The cash availability in the books and the business activity were not in dispute, but the explanation for the specific HDFC deposit was not fully satisfactory. The record showed a large cash balance and substantial deposits in another bank account, yet the explanation did not clearly establish that the entire amount deposited in HDFC Bank was fully explained in the manner claimed. At the same time, the material did not justify sustaining the entire addition, since the deposit formed part of the overall cash flow and business receipts.

Conclusion: The addition was not sustainable in full, and only 50% of the deposit was upheld; the balance 50% was directed to be deleted, resulting in partial relief to the assessee.

Issue (ii): Whether the amount sustained could be subjected to tax under section 115BBE for Assessment Year 2017-18.

Analysis: The rate of tax under section 115BBE was examined in the context of the assessment year involved. The applicable legal position was taken to be that the enhanced manner of taxation under that provision did not apply to Assessment Year 2017-18, and the sustained addition was therefore required to be taxed in the ordinary manner applicable to the assessee.

Conclusion: The sustained addition was directed to be taxed at the normal rate and not under section 115BBE for Assessment Year 2017-18.

Final Conclusion: The assessee obtained partial relief because the impugned addition was cut down by half, while the balance was maintained and directed to be taxed under the ordinary provisions rather than the special deeming rate.

Ratio Decidendi: Where a cash deposit is only partly left unexplained on the facts, the addition may be restricted to the unexplained portion, and the special tax rate under section 115BBE cannot be applied to Assessment Year 2017-18 in the manner sought by the Revenue.

Issues: Whether the penalty imposed under Section 112 of the Customs Act, 1962 was sustainable when the goods were cleared on the basis of a Pre-Shipment Certificate issued by Bangladesh University of Textiles.

Analysis: The goods were assessed and cleared by the Customs authorities on the basis of the Pre-Shipment Certificate, and no objection was raised at the time of clearance. A prior communication from the Deputy High Commission of the People's Republic of Bangladesh certified that the institution, then known as the College of Textile Technology and later as Bangladesh University of Textiles, was a government organisation authorised to issue certificates regarding AZO and hazardous dyes. No contrary corroborative evidence was produced by the Revenue to discredit that certificate or to show any offence by the importer.

Conclusion: The Pre-Shipment Certificate was held to be valid, and the appellant was found not to have committed any offence warranting penalty under Section 112 of the Customs Act, 1962.

Final Conclusion: The penalty was set aside and the appeal was allowed with consequential relief.

Ratio Decidendi: When imported goods are cleared on the basis of a certificate that is shown to be issued by an authorised body and the Revenue produces no contrary evidence, penalty under Section 112 of the Customs Act, 1962 cannot be sustained.

Issues: (i) Whether cross-objections filed by the respondent survive for consideration on merits after withdrawal of the departmental appeal under the Government Litigation Policy. (ii) Whether the imported vehicle, declared as used but found to be new and imported without compliance with import-policy and vehicle-law requirements, is liable for confiscation under Section 111(d) of the Customs Act, 1962, and whether absolute confiscation was justified or redemption ought to have been allowed.

Issue (i): Whether cross-objections filed by the respondent survive for consideration on merits after withdrawal of the departmental appeal under the Government Litigation Policy.

Analysis: Section 129A(4) of the Customs Act, 1962 treats cross-objections as an independent statutory proceeding and requires them to be disposed of as if they were an appeal filed in time. Once cross-objections are duly filed, withdrawal of the main departmental appeal does not automatically extinguish the respondent's challenge to the adverse part of the order. The respondent's objection to absolute confiscation therefore required independent adjudication.

Conclusion: The cross-objections were maintainable and had to be decided on merits notwithstanding withdrawal of the departmental appeal.

Issue (ii): Whether the imported vehicle, declared as used but found to be new and imported without compliance with import-policy and vehicle-law requirements, is liable for confiscation under Section 111(d) of the Customs Act, 1962, and whether absolute confiscation was justified or redemption ought to have been allowed.

Analysis: The vehicle was found to have been mis-declared as used and imported in breach of the regulatory conditions governing import of motor vehicles. Such violation attracts confiscation under Section 111(d) of the Customs Act, 1962, but the goods were not held to be prohibited goods in the strict sense. In the absence of exceptional reasons, and having regard to the statutory scheme of redemption under Section 125 of the Customs Act, 1962, absolute confiscation was considered excessive. The appropriate course was confiscation with an option to redeem on payment of redemption fine and applicable duties.

Conclusion: Confiscation under Section 111(d) was upheld, but absolute confiscation was set aside and redemption was directed on payment of redemption fine and applicable duties.

Final Conclusion: The respondent succeeded to the extent that the vehicle was not to remain absolutely confiscated, while the finding of confiscability was sustained and the matter was finally disposed of by allowing redemption on specified monetary terms.

Ratio Decidendi: Cross-objections under Section 129A(4) of the Customs Act, 1962 survive the withdrawal of the main appeal, and goods imported in breach of regulatory import conditions but not absolutely prohibited should ordinarily be released against redemption rather than subjected to absolute confiscation.

Issues: Whether the order of the National Company Law Tribunal suffered from violation of principles of natural justice so as to justify writ interference despite availability of an appellate remedy under the Insolvency and Bankruptcy Code, 2016.

Analysis: Upon admission of a petition under section 7, the insolvency process becomes a proceeding in rem and the management of the corporate debtor vests in the interim resolution professional. An application for withdrawal under section 12-A, read with Regulation 30-A, had to be moved through the interim resolution professional, who represented the corporate debtor in the insolvency process. The respondents opposing withdrawal were financial creditors with a direct stake in the proceedings, and they were heard by the adjudicating authority. The petitioners' reliance on lack of direct hearing was misplaced because the suspended management had no independent right to bypass the statutory framework, and the record also showed that the petitioner financial creditor had authorised the interim resolution professional to move the withdrawal application. The existence of an alternate statutory appeal and the constitution of the committee of creditors further supported restraint in writ jurisdiction.

Conclusion: The order of the National Company Law Tribunal did not suffer from breach of natural justice, and writ interference was not warranted.

Issues: (i) whether the demand of service tax on advances received was barred by limitation and whether the extended period could be invoked; (ii) whether CENVAT credit could be denied solely because it was not reflected in the ST-3 returns and was taken beyond the procedural time limit; (iii) whether penalty under Section 78 was sustainable; and (iv) whether interest on the delayed payments of service tax was payable.

Issue (i): whether the demand of service tax on advances received was barred by limitation and whether the extended period could be invoked.

Analysis: The demand arose from scrutiny of the appellant's statutory records, including balance sheets, ST-3 returns and profit and loss accounts, all of which were available to the Department. The record did not show any positive act of suppression, wilful misstatement, fraud, collusion, or intent to evade tax. In the absence of corroborative material establishing mens rea, the conditions for invoking the extended period were not satisfied.

Conclusion: The demand of service tax on advances received was held to be barred by limitation and was set aside.

Issue (ii): whether CENVAT credit could be denied solely because it was not reflected in the ST-3 returns and was taken beyond the procedural time limit.

Analysis: The appellant had paid service tax to the subcontractor and the genuineness of the transaction and payment was not in dispute. The credit claimed was a substantive entitlement and the only objection was non-reporting in the returns and delayed availment. Procedural omissions that do not affect the underlying eligibility cannot defeat a vested credit when the tax payment and supporting documents are established. The reasoning was reinforced by prior Tribunal decisions holding that substantive credit cannot be denied on mere procedural irregularities.

Conclusion: The appellant was held entitled to the CENVAT credit and its denial on procedural grounds was unsustainable.

Issue (iii): whether penalty under Section 78 was sustainable.

Analysis: Penalty under Section 78 requires fraud, collusion, wilful misstatement, suppression of facts, or intent to evade payment. The appellant was registered, maintained records, made voluntary payments for other liabilities, and the demand itself arose from audited records. Since the same factual foundation failed to establish suppression for limitation, it also did not justify penal action.

Conclusion: The penalty under Section 78 was set aside in toto.

Issue (iv): whether interest on the delayed payments of service tax was payable.

Analysis: The appellant did not dispute that service tax on two components had been paid belatedly. Once delay in payment was admitted, the liability to pay interest followed as a consequential statutory consequence.

Conclusion: Interest on the delayed payments was upheld and not interfered with.

Final Conclusion: The principal demand and penalty were annulled, the credit-related objection was rejected in favour of the assessee, and only the admitted interest liability and the undisputed remaining demands survived.

Ratio Decidendi: Extended-period demands require proven suppression or equivalent culpable conduct, and a substantive tax credit cannot be denied merely for procedural non-compliance where eligibility and payment are otherwise established.

Issues: Whether CENVAT credit of service tax paid on GTA service used for outward transportation of goods up to the customer's premises was admissible, having regard to the place of removal under the valuation provisions and the definition of input service.

Analysis: The admissibility of credit depended on whether the customer's premises constituted the place of removal on the facts of the sale. Section 4 of the Central Excise Act, 1944 links assessable value to the transaction value at the time and place of removal, and the definition of input service in Rule 2(l) of the CENVAT Credit Rules, 2004 covers outward transportation up to the place of removal. The purchase orders and invoices showed delivery on FOR door delivery terms, and payment was to be made only on receipt of goods in proper condition, indicating that the sale was completed upon delivery at the buyer's premises. In such a situation, the outward transportation was within the scope of input service.

Conclusion: CENVAT credit on GTA service for transportation up to the customers' premises was admissible, the customers' premises being the place of removal on the facts of the case.

Issues: Whether the addition for unexplained cash credit was sustainable where the impugned receipt was explained as an advance received from a purchaser towards sale of a residential unit.

Analysis: Under Section 68 of the Income-tax Act, 1961, the credit was supported by the purchaser's bank record showing debit of the amount and the assessee's bank record showing corresponding credit on the same date. The registered agreement for sale of the unit also substantiated that the receipt represented sale advance rather than an unsecured loan or unexplained credit.

Conclusion: The addition under Section 68 was unjustified and was deleted in favour of the assessee.

Issues: (i) Whether reliance on undisclosed third-party statements without effective cross-examination violated principles of natural justice; and (ii) Whether documented sale proceeds from listed shares could be treated as unexplained cash credit under section 68 and the related long-term capital-gain exemption denied.

Issue (i): Whether reliance on undisclosed third-party statements without effective cross-examination violated principles of natural justice.

Analysis: The addition rested partly on statements of alleged operators, but copies of those statements were not supplied and effective cross-examination was not provided. The applicable requirement of natural justice mandated disclosure and an opportunity to test adverse third-party material relied upon for assessment.

Conclusion: Reliance on undisclosed third-party statements without effective cross-examination violated principles of natural justice, in favour of the assessee.

Issue (ii): Whether documented sale proceeds from listed shares could be treated as unexplained cash credit under section 68 and the related long-term capital-gain exemption denied.

Analysis: The share acquisition was through preferential allotment with payment through banking channels; the shares were credited to the demat account, sold through recognised stock exchanges using registered brokers, and the sale proceeds were received through banking channels. These documentary records remained unrebutted. General investigation reports, abnormal price movement, and alleged suspicious counterparties did not establish any nexus, collusion, prior arrangement, cash trail, or price-manipulation role of the assessee. The securities regulator's findings that no connection was established between the preferential allottees and price-rigging entities were relevant evidentiary material. The test of human probabilities could not override direct, unrebutted documentary evidence in the absence of cogent corroborative material.

Conclusion: The sale proceeds could not be treated as unexplained cash credit under section 68, and the addition was deleted, in favour of the assessee.

Final Conclusion: The documented long-term capital-gain transaction remained uncontroverted, and the consequential alleged-commission addition under section 69C could not survive.

Ratio Decidendi: An addition for alleged penny-stock accommodation entries cannot rest on general investigation material and suspicion where documentary evidence remains unrebutted and no nexus, cash trail, or collusion with the assessee is established.

Issues: Whether the applicant satisfied the twin conditions for regular bail under Section 45 of the Prevention of Money Laundering Act, 2002.

Analysis: Section 45 requires reasonable grounds to believe that the accused is not guilty of money laundering and is not likely to commit an offence while on bail. The material, including statements recorded under Section 50 of the Prevention of Money Laundering Act, 2002, bank transactions, acquisition of properties through the company, unsecured loans, and financial links with the co-accused, prima facie indicated the applicant's active participation in concealing, acquiring, using, and projecting proceeds of crime as untainted. Statements under Section 50 are admissible material at the bail stage. The pattern of coordinated transactions, multiple accounts, and involvement of associates also indicated a risk of further similar activity if released. The gravity and organised nature of the alleged economic offence warranted application of the statutory rigours.

Conclusion: The applicant failed to satisfy either of the twin conditions under Section 45 of the Prevention of Money Laundering Act, 2002; the issue is decided against the applicant.

Issues: Whether the denial of a requested video-conferencing hearing in faceless appellate proceedings warranted setting aside the appellate order for fresh adjudication.

Analysis: Paragraph 12 of the Faceless Appeal Scheme, 2021 requires the Commissioner (Appeals) to allow a requested personal hearing, to be conducted through video conferencing or video telephony. The assessee's request for video-conferencing hearing was undisputedly made but was not considered before the appellate order was passed. This constituted denial of the prescribed hearing opportunity and breach of principles of natural justice.

Conclusion: The appellate order was set aside and the matter was restored for de novo adjudication after granting the assessee a video-conferencing hearing; the issue was decided in favour of the assessee.

Issues: (i) Whether the assessee was entitled to claim the benefit of the new tax regime under section 115BAC despite not filing a fresh Form 10IE for the assessment year under appeal. (ii) Whether the adjustment made while processing the return under section 143(1) to deny the new tax regime was sustainable.

Issue (i): Whether the assessee was entitled to claim the benefit of the new tax regime under section 115BAC despite not filing a fresh Form 10IE for the assessment year under appeal.

Analysis: The option under section 115BAC(5)(i) for a person having income from business or profession is to be exercised in the prescribed manner and, once exercised, applies to subsequent assessment years. The assessee had earlier opted for the new regime and filed Form 10IE for the preceding year. The Tribunal followed coordinate bench decisions holding that the belated filing of Form 10IE in the earlier year did not invalidate the exercise of option itself, and that no fresh Form 10IE was required for the subsequent year so long as the earlier option had not been withdrawn and the return for the year under appeal was filed within the due date under section 139(1).

Conclusion: The assessee was entitled to continue under the new tax regime, and denial of the benefit for want of a fresh Form 10IE was unjustified.

Issue (ii): Whether the adjustment made while processing the return under section 143(1) to deny the new tax regime was sustainable.

Analysis: Since the assessee's option under section 115BAC continued to operate for the relevant year, the computation of tax under the normal regime and the resulting demand were based on an incorrect denial of that option. The adjustment under section 143(1) could not be sustained on the premise that the assessee was ineligible for the concessional regime merely because no fresh Form 10IE was filed for the year under appeal.

Conclusion: The processing adjustment and the consequential demand were not sustainable.

Final Conclusion: The denial of the new tax regime was set aside and the assessment was directed to be modified by allowing the assessee's claim under section 115BAC.

Ratio Decidendi: Where the assessee had validly opted for the new tax regime in an earlier year and had not withdrawn that option, the benefit continues for subsequent years under section 115BAC(5)(i), and the absence of a fresh Form 10IE for the later year does not by itself invalidate the claim.

Issues: Whether the deletion of disallowance for alleged non-deduction of tax could be sustained without verification of the character of the payments, the residential status of recipients, and the underlying transaction documents.

Analysis: Neither the assessment nor the appellate proceedings involved adequate inquiry into the conditions for application of section 194Q, including whether the payments represented consideration for goods and whether they were made to residents. The appellate conclusion was based on sample transactions and presumptions drawn from the names of shipping companies, without a thorough examination of the relevant documents. The co-terminus appellate powers required verification of the transactions, including possible tax-deduction liability under the applicable provisions.

Conclusion: The appellate deletion could not be sustained without proper factual verification, and fresh adjudication by the first appellate authority was required.

Issues: (i) Whether transfer of inherited tenancy rights in an identified residential flat is chargeable to capital gains tax despite absence of proven historical cost; (ii) Whether the claimed fair market value as on 1 April 2001 and consequential indexed cost require verification for recomputation of capital gains.

Issue (i): Whether transfer of inherited tenancy rights in an identified residential flat is chargeable to capital gains tax despite absence of proven historical cost.

Analysis: Sections 45 and 48 of the Income-tax Act, 1961 operate as an integrated charging and computation scheme. The tenancy rights transferred were connected with an identified immovable property, were transferred for quantified consideration, and were capable of valuation by reference to the underlying property and market conditions. The inability to establish the cost in the hands of the previous owner creates a question of quantification; it does not cause a failure of the computation machinery. Acquisition through a will does not, by itself, render an otherwise identifiable and marketable capital asset outside the capital-gains charge.

Conclusion: Against the assessee, the transfer of tenancy rights is chargeable under the head capital gains; the plea of complete non-chargeability is rejected.

Issue (ii): Whether the claimed fair market value as on 1 April 2001 and consequential indexed cost require verification for recomputation of capital gains.

Analysis: The valuation report furnished for the fair market value as on 1 April 2001 had not been examined on merits, and the earlier non-reference for valuation resulted from time constraints rather than a reasoned assessment of that report. Determination of the applicable fair market value and indexed cost of acquisition requires factual and, where necessary, technical verification under the statutory computation framework.

Conclusion: In favour of the assessee to the limited extent, the valuation report must be examined and the fair market value as on 1 April 2001, together with the consequential indexed cost of acquisition, must be determined in accordance with law.

Final Conclusion: The capital-gains charge survives, while the taxable quantum remains to be computed upon lawful determination of the fair market value and consequential indexation.

Ratio Decidendi: Where tenancy rights connected with specified immovable property are transferable and capable of valuation, absence of an established acquisition cost consequent to inheritance does not make capital-gains computation unworkable or exclude the transfer from charge.

Issues: (i) Whether the assessments under sections 153A/153C could be challenged for absence of incriminating search material in unabated years; (ii) Whether the bank deposits were assessable as unexplained income despite the documented sources; (iii) Whether rough seized salary computations supported additions for undisclosed salary income; (iv) Whether a mobile-phone noting of gold quantity and value supported an addition for unexplained jewellery investment.

Issue (i): Whether the assessments under sections 153A/153C could be challenged for absence of incriminating search material in unabated years.

Analysis: Sections 153A and 153C of the Income-tax Act, 1961 govern search-related assessments. Though completed assessments ordinarily require incriminating search material for additions, the record reflected seized documents having an indirect link with the additions. The challenge based on absence of incriminating material was therefore not accepted on the facts.

Conclusion: The jurisdictional challenge to the assessments under sections 153A/153C is rejected. This is against the assessee.

Issue (ii): Whether the bank deposits were assessable as unexplained income despite the documented sources.

Analysis: The evidentiary burden shifts after a reasonable explanation of the source of funds is supported by material. Fund-flow details, regular cash withdrawals, salary receipts, savings, transfers, interest credits, recurring-deposit maturity proceeds, provident-fund receipts, property-sale proceeds and advances explained the deposits. The deposits were modest, spread over several years and consistent with the financial profile; deposits in the joint account also reflected the independent sources of both account holders. Suspicion or presumption could not displace this evidence.

Conclusion: The additions for unexplained bank deposits are deleted. This is in favour of the assessee.

Issue (iii): Whether rough seized salary computations supported additions for undisclosed salary income.

Analysis: The evidentiary value of loose papers depends on corroboration by actual transactions or independent evidence. The seized rough calculations represented an estimate or salary-negotiation projection and did not establish actual receipt of the computed amounts. There was no employer confirmation or other corroborative material, and statements recorded during search could not overcome the absence of evidence of actual income.

Conclusion: The additions for alleged undisclosed salary income are deleted. This is in favour of the assessee.

Issue (iv): Whether a mobile-phone noting of gold quantity and value supported an addition for unexplained jewellery investment.

Analysis: CBDT Instruction No. 1916 dated 11.05.1994 provided relevant norms for jewellery held by family members. The aggregate jewellery found was within reasonable limits having regard to the family composition. The mobile noting did not establish an actual purchase, and no purchase bills, financial trail or other corroborative evidence supported an unexplained investment. An ambiguous noting and conjecture could not substitute proof.

Conclusion: The addition for alleged unexplained jewellery investment is deleted. This is in favour of the assessee.

Final Conclusion: The income additions based on bank deposits, alleged salary receipts and jewellery are unsustainable for want of adequate evidence, while the validity of the search-assessment jurisdiction remains intact.

Ratio Decidendi: Additions founded on bank deposits or informal seized notings require an adequate evidentiary foundation; a documented explanation of source or an uncorroborated rough notation cannot, without more, sustain an addition.

Issues: Whether reassessment jurisdiction could validly be assumed by treating the assessee as a non-filer despite a return of income having been filed for the relevant assessment year.

Analysis: Reassessment under Section 147 requires a valid factual foundation and application of mind to the material available with the Assessing Officer. The notice under Section 148A(b), the order under Section 148A(d), and the reassessment proceeded on the premise that no return had been filed, although the return under Section 139(1) was on record. Reliance merely on portal information without verifying the assessee's return record rendered the recorded satisfaction factually erroneous and jurisdictionally unsustainable.

Conclusion: The reassessment proceedings were invalid in law; the jurisdiction assumed under Section 147 and the consequential reassessment order were set aside, in favour of the assessee.