Conditional remand cannot extinguish statutory appeal rights; invalid ex parte orders require fresh reasoned merits adjudication.

Retrospective tax amendments cannot create new liability for offshore technical services or override favourable treaty interpretation.

Inter-co-operative society interest exemption protects co-operative banks from withholding tax on deposits paid to non-member societies.

Finality of judicial findings required compounding fee recomputation under earlier guidelines, barring application of later revised guidelines.

Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...

Reassessment procedure: participation may cure objections to an absent scrutiny notice, while additions must retain nexus with recorded reasons.

Reasonable cause for notice non-compliance during pandemic disruption prevented penalty for a technical default by an educational trust.

Charitable trust exemption survives section 13 violations except to the extent income benefits specified persons or trustees.

Balance-sheet reclassifications do not create taxable income without a profit-and-loss debit, deduction claim, or established charging basis.

Bona fide deduction claims and unspecified penalty notices prevent under-reporting penalty under section 270A.

Permanent establishment requirements were unmet, so offshore supply and repair receipts remained outside Indian taxation under the treaty.

HUF property taxation: individual ownership evidence excluded stamp-duty value difference from taxation under the deemed receipt provision.

Binding interim judicial directions protected employers from withholding default on foreign-leg leave travel concession payments despite later clarifi...

Rectification jurisdiction excludes debatable income computation, leaving capital receipt and expenditure treatment for appellate determination.

Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...

Jurisdictional notice requirement invalidates scrutiny assessments when the assessing officer completing assessment issued no statutory notice.

Reasonable cause for emergency cash loans protected genuine acceptance and repayment transactions from statutory penalties.

Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...

Credible material of corruption is required for an independent investigation; clearance delays and valuation disputes alone are insufficient.

Baggage import jurisdiction remains outside Tribunal appeals, directing confiscation and penalty disputes to the statutory revisional remedy.