Interim stay orders: prioritize prompt administrative action to protect revenue where balance of convenience favors the government.
The instruction requires immediate administrative action when High Courts grant ad interim stay orders to protect revenue, emphasizing prompt steps under the constitutional judicial review framework and noting the Supreme Court's observation that the balance of convenience in fiscal disputes favors the Government; interim orders should not be routinely enclosed and must be handled to minimize prejudice to the Government's fiscal position.

Tax deducted at source fraud demands stricter verification of TDS certificates, challans and return reconciliations.
Fraudulent refund claims were made using bogus tax deducted at source certificates and by failing to deposit TDS within statutory periods. The directive identifies deficiencies: absent or perfunctory checks that tax was actually deducted on interest, that deducted tax was paid to the Central Government, and that quarterly Form No.26A and challans were filed and recorded. Assessing officers have neglected registers, return fields and verification of creditors' accounts and challans. The instruction requires reiteration of procedural checks, reconciliation of returns and challans, and maintenance of registers to prevent such fraud.

Depreciation recalculation: companies must recompute specified period and adjust straight-line charges after tax-rate changes per statutory guidance.
Companies using the straight line method must recalculate the specified period under revised income-tax depreciation rates by: identifying years already depreciated, computing the specified period under revised rates by which the prescribed residual of original cost is depleted on written down value basis, noting written down value at the rate-change year start, and residual value. Thereafter, fixed annual instalments equal (written down value minus residual value) divided by remaining recalculated years must be charged; if years already depreciated exceed the recalculated period, the balance may be provided as depreciation in the year of change.

Substance-over-form doctrine treats prearranged tax-avoidance steps collectively for fiscal assessment, reflecting economic reality.
Judicial approach treats prearranged, multi-step tax avoidance schemes by assessing the aggregate fiscal effect-comparing the position after the final step with that before the first-and taxes according to the substantive economic outcome rather than isolated formal steps. Courts may also lift the corporate veil in exceptional cases where a company is used to circumvent tax obligations, applying an economic-reality test so that informal arrangements cannot defeat tax assessment.

Speaking orders require recording reasons in quasi judicial decisions to prevent arbitrary action and enable review.
Authorities exercising quasi judicial functions must issue speaking orders supported by recorded reasons. Recording reasons prevents arbitrary decision making, excludes irrelevant considerations, enables an aggrieved party to challenge erroneous reasoning, and facilitates judicial review; accordingly, tax departmental authorities must apply their minds and state the basis for their conclusions when issuing final orders.