Extended limitation for service-tax recovery under the proviso to Section 73(1) requires specific pleading and proof of fraud, wilful misstatement, suppression of facts, or contravention committed with intent to evade tax. Revenue bears the burden of establishing such mala fide conduct. Non-collection of service tax, coupled with a bona fide belief that works-contract services were exempt, does not by itself demonstrate deliberate intent to evade. Where the available material does not establish the required intent, the extended period cannot support recovery and the demand is barred by limitation.

Appeals concerning baggage imported under the Customs Act, 1962 and the Baggage Rules, 1998 fall within the Central Government's revisionary jurisdiction rather than the Tribunal's appellate jurisdiction. An appeal on such baggage matters is therefore not maintainable before the Tribunal. The prescribed remedy is a revision application to the Central Government under the Customs Act.

Transfer-pricing analysis under the Transactional Net Margin Method requires turnover and functional comparability: high-turnover, diversified, product-based, or otherwise functionally distinct entities should be excluded, and working-capital adjustments calculated from actual data should not be arbitrarily capped. A timely reference to the Transfer Pricing Officer triggers the extended assessment limitation period. For Section 10A, expenditure excluded from export turnover must also be excluded from total turnover, and the deduction is computed undertaking-wise before gross-total-income reductions, subject to verification of relevant figures. Employee misappropriation incidental to business may be deductible in the year discovered, subject to evaluation of recovery evidence and consequential adjustment to eligible undertaking profits.

Where a property purchaser disputes the stamp-duty valuation used to compute the taxable consideration difference under Section 56(2)(x)(b), a Departmental Valuation Officer's valuation is required before that difference is adjudicated for income-tax purposes. The assessment must be reconsidered on the Departmental Valuation Officer's valuation, and the assessee must substantiate its position during the fresh proceedings.

Eligibility for deduction under Section 80P required factual verification because the statutory audit report in Form 3CA/3CD was produced before the Tribunal rather than before the lower authorities. Although the return was treated as timely filed in light of the audit requirement, the report's verification and its effect on deduction eligibility required examination. The deduction claim was remitted to the Assessing Officer for fresh adjudication after providing the assessee an opportunity, without a final determination on eligibility.

Section 151 approval for reassessment must demonstrate the approving authority's independent application of mind through recorded satisfaction. A same-day online endorsement stating only "approved", without reasons or discernible satisfaction, constitutes mechanical sanction and does not support valid assumption of jurisdiction under Sections 147 and 148; the reopening proceedings consequently fail. Section 253(5) permits condonation where sufficient cause is established: an inadvertent, non-malafide filing oversight supported by affidavit justified condonation of the delay in filing the appeal.

Penalty for non-compliance with a statutory notice requires actual defiance. A written response received before the stipulated hearing date constitutes compliance, even where it challenges the jurisdictional basis of the proceedings. Non-filing differs from filing a response that the Assessing Officer considers unsatisfactory; dissatisfaction with the response cannot establish default. Because the response was received but not considered before the penalty was imposed, the alleged non-compliance was unproved, rendering the penalty unsustainable and requiring the penalty orders to be quashed.

The Income-tax Act permits penalties for failure to comply with scrutiny notices. In faceless assessments, notices are served electronically, and communication gaps may prevent effective compliance. Non-compliance attributable to circumstances beyond the taxpayer's control may therefore be justified rather than treated as deliberate non-cooperation. On that basis, the penalty for failure to respond to scrutiny notices was deleted.

Assessment proceedings under Section 144 cannot be sustained against a company struck off from the register before the assessment was framed where the proceedings themselves commenced after strike-off. Governing precedent treats the company's removal from the register as preventing continuation of the assessment mechanism, with the resulting assessment liable to be quashed.

For assessment year 2018-19, exemption under Section 10(23C)(iiiad) applied by testing the annual receipts of each educational institution separately. Receipts of multiple institutions run by the same society could not be aggregated merely because their collective receipts exceeded the prescribed limit. The later amendment effective from 1 April 2022, which requires aggregation at the level of the person running multiple institutions, did not apply to that assessment year. Each institution remaining below the prescribed limit therefore qualified for exemption.

Reassessment jurisdiction under Sections 147 and 148 requires recorded reasons based on correct and verified foundational facts. A recorded premise that no return was filed is unsustainable where the return, its acknowledgement, and a refund issued on its basis are already on record. Making a cash-deposit addition without considering returned income further demonstrates non-application of mind. On these facts, the reassessment notice, consequential proceedings, and best-judgment assessment were void ab initio for invalid assumption of jurisdiction.

Search-based assessment founded entirely on material seized from another person falls within the special regime under Sections 153A and 153C, which overrides regular reassessment under Sections 147 and 148. Where seized material belongs or relates to a person other than the searched person, proceedings must be initiated under Section 153C after its statutory conditions are met. Sections 147 and 148 remain available for regular reassessment and matters not based on incriminating search material. Without distinct material outside the search, reopening under Sections 147 and 148 is legally untenable.

Employees' contributions to provident fund and ESIC deposited after the due dates under the relevant welfare laws are not deductible under section 36(1)(va), even where payment occurs before the income-tax return filing date; section 43B does not extend that benefit to employees' contributions. From AY 2017-18, ICDS VI requires exchange differences on specified forward contracts hedging export receivables to be recognised on settlement. Accordingly, a year-end marked-to-market gain recorded under AS-11 on unsettled hedging contracts is excluded from taxable business income where the entry is reversed and the actual gain or loss is recognised upon settlement.

Binding precedent requires statutory set-off of brought-forward unabsorbed business losses after verification and in accordance with law. A pending Revenue challenge to an earlier appellate direction does not displace that obligation unless a higher appellate forum reverses the direction. In the absence of material establishing prior compliance or any infirmity in the direction, the Assessing Officer must give effect to the statutory set-off if it has not already been allowed.

Verification of sale agreements reconciled reported flat sales, so an addition based on AIR information and the percentage completion method was deleted. A 1% project interest recorded in audited financial statements was not unexplained investment under Section 69B, sustaining deletion of that addition. For alleged non-genuine purchases under Section 69C, only the profit element was estimated at 12.5% of the impugned purchases, and restriction of the addition to that extent was sustained.

Reassessment for AY 2014-15 cannot proceed where the original notice under Section 148 was issued after the limitation prescribed by the first proviso to Section 149. A time-barred and invalid notice cannot be deemed to be a notice under Section 148A(b), despite a subsequent order under Section 148A(d). Where commodity transactions and broker receivables were disclosed in the accounts and return, the record does not establish income escaping assessment represented by an asset exceeding the statutory threshold. The reassessment initiation was therefore invalid.

Cash deposits made during the demonetisation period require verification against month-wise cash sales, bank deposits and VAT returns before they can be treated as unexplained money. Where those records indicate a stated source, audit reports and Forms 3CA and 3CD must also be examined to determine the validity of both the unexplained-money addition and net-profit estimation. Fresh verification by the Assessing Officer, after providing an opportunity of hearing, is necessary before adjudicating these issues.

Prior sanction from the authority specified under Section 151 is a jurisdictional precondition for reassessment notices issued after three years from the end of the relevant assessment year, where the alleged escaped income exceeds the prescribed threshold. Approval must then come from the statutorily designated senior tax authority. The transitional relaxation does not dispense with that requirement. Notices approved by an incompetent authority are void ab initio, and consequential reassessment proceedings are invalid.

Cash receipts claimed as gifts require reliable evidence establishing the gift's genuineness, the donor's financial capacity, and the availability and retention of cash at the relevant time. A donor certificate and land-sale particulars were insufficient where sale proceeds arose after the last alleged gift and no evidence established cash withdrawals or the manner in which the donor or recipient held the cash. The claimed cash gift was therefore not satisfactorily explained and was treated as unexplained income.

Registered educational trusts with subsisting registration under sections 12A and 12AA retain their trust status for section 11 purposes. Assessment and appellate authorities cannot treat fee-charging educational activity as non-charitable by disregarding that registration; scrutiny of compliance with statutory requirements falls to the Commissioner. On that basis, denial of section 11 exemption and the related addition is unsustainable.