Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.

Reassessment proceedings alleging fictitious mutual-fund losses and dividend income were quashed where the taxpayer was identically situated to one covered by a final earlier decision and the Revenue did not dispute its applicability. The order under section 148A(d) and the notice under section 148 were set aside because the earlier ruling had already quashed materially similar reassessment action on identical facts.

Section 119(2)(b) permits condonation of delay in a revised return seeking refund to prevent genuine hardship, subject to the prescribed six-year limit. The competent authority must independently determine whether the refund claim is correct and genuine and whether genuine hardship exists; this power cannot be exercised routinely. A rejection cannot rest on irrelevant considerations or an unreasoned denial of hardship, and recorded reasons cannot be supplemented in court. The sufficient-cause standard for delayed appeals under the Limitation Act does not impose a stand-alone requirement to explain delay under section 119(2)(b). The refusal to condone was quashed and remitted for a fresh reasoned decision, leaving the exemption claim open.

Tariff-related debit notes seeking reimbursement of income tax as an electricity-tariff component involve disputed questions requiring specialised adjudication before CERC. Writ jurisdiction did not extend to examining the merits of the debit notes or the claimed liability. The generating company was required to pursue the regulatory remedy before CERC, which was to decide the dispute expeditiously after hearing all parties. The writ petition was disposed of on that basis.

Unverified Insight Portal information cannot justify reassessment where it does not identify any transaction linking the taxpayer to alleged escaped income. Reassessment must rest on material demonstrating a taxpayer-specific nexus and application of mind; it cannot be used for a roving and fishing inquiry. Where the underlying material is not supplied, the alleged-beneficiary chart identifies no attributable transaction, and the Assessing Officer does not verify the information's genuineness, the reassessment notice and order under section 148A(3) lack a valid foundation. The reassessment proceedings were quashed and the writ petition was allowed.

Statutory transfer of an income-tax case gives the transferee Assessing Officer exclusive jurisdiction over pending, completed and future proceedings for every covered year. PAN database records do not determine or retain jurisdiction after transfer. Reassessment requires a notice issued by the jurisdictional Assessing Officer; a notice issued by the transferor officer is without jurisdiction and non-est. Consequently, the reassessment notice for the relevant assessment year and all resulting proceedings were quashed.

Deletion of a negative working-capital adjustment in rectification proceedings required implementation through a consequential appeal-effect order. The Assessing Officer was required to consider whether, after that deletion, the taxpayer's margin fell within the permissible arm's-length range and could reach a contrary conclusion only after giving a reasonable opportunity of hearing. The appeal-effect order was directed to be passed within 15 days, with liberty to seek revival if the consequential order caused grievance.

Valid adoption of the DCF method for valuing unquoted equity shares under Rule 11UA requires any assessment correction to remain within that method. Management projections, historical losses, or later financial results may justify scrutiny of assumptions, growth rates, discount factors, terminal value and market conditions, but do not alone permit substitution of the NAV method. Rejection requires identified arithmetical errors, internal inconsistencies, factual inaccuracies, or inputs demonstrably contrary to contemporaneous material or industry norms. Applying these principles, the addition under section 56(2)(viib) was deleted and the Revenue's appeal was dismissed.

Discounted cash flow valuation of equity shares and compulsorily convertible preference shares must be assessed as at the valuation date; subsequent actual cash flows, initial operating losses, or absence of positive cash flows do not alone invalidate projections. Substitution of the discounted cash flow method with net asset value valuation was therefore inappropriate, and the share-premium addition was deleted. Vendor-confirmation differences did not justify treating recorded business expenses as unexplained where audited books recorded the transactions, payments passed through banking channels, and business operations funded the expenditure; the unexplained-expenditure addition was deleted. Penalty-initiation challenges were premature because penalty proceedings remain separate from assessment proceedings.

Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.

Territorial jurisdiction over an income-tax appeal and a related cross-objection is ordinarily determined by the office location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the appellate authority. Where the assessment order originated from the Chennai Assessing Officer, the Mumbai Bench lacked jurisdiction over both proceedings. The appeal and cross-objection were dismissed without examination on merits, with liberty to approach the appropriate Bench. Merits remained open, and time spent before the Mumbai Bench may be considered under delay-condonation law.

Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.

Section 54 relief for construction of a new residential house depends materially on completion within the statutory three-year period after transfer of the original asset; construction commencing before that transfer does not by itself prevent relief. Valuation-supported construction expenditure, separately identifiable from land cost, qualifies for deduction where timely completion is established. Land may form part of a new residential house investment only if its acquisition and construction satisfy the prescribed conditions. A plot acquired outside the applicable period and registered in the spouse's name is excluded, and a later settlement in favour of the assessee does not establish entitlement for the relevant year. Relief is therefore confined to eligible construction cost.

Reopening of a concluded scrutiny assessment beyond four years requires recorded reasons that independently demonstrate tangible material, a rational link to income escaping assessment, and the taxpayer's failure to make a full and true disclosure of primary facts. Recorded reasons containing factual errors and no connection between an alleged entry operator and the shareholder do not establish due application of mind or a valid reason to believe. Disclosure of shareholder details, banking particulars and confirmations satisfies the taxpayer's obligation; the taxpayer need not draw further factual or legal inferences for the Assessing Officer. The reopening and consequential reassessment were void ab initio and quashed.

Rectification jurisdiction permits correction only of a patent, manifest or self-evident error, not reassessment of evidence or review of an earlier view. Claims that additions for alleged on-money receipts failed to consider seized material, related orders, a co-ordinate Bench decision and precedents on income extrapolation did not establish a mistake apparent from the record where those materials had been considered. The rectification applications therefore amounted to an impermissible review and were dismissed.

Cash-payment disallowance under section 40A(3) depends on whether payments exceeding the prescribed daily limit were made to a single person, not merely on a voucher exceeding that limit. A consolidated voucher may record separate payments to multiple persons, each within the limit, and therefore may not establish a contravention. Supporting material omitted by an erstwhile tax consultant was admitted as additional evidence because the first appellate order had been passed without it. The ex parte appellate order and cash-payment disallowance were set aside and remitted to the Assessing Officer for verification and fresh adjudication, with all contentions left open.

Rectification for a mistake apparent from the record is limited to patent, manifest and self-evident errors identifiable without prolonged reasoning. Detailed challenges to remand directions on an AMP transfer-pricing adjustment or an associated-enterprise share purchase seek a review on merits and fall outside section 254(2); those rectification requests fail. Omission to decide an unrebutted claim for TDS credit constitutes a rectifiable omission. Supporting evidence requires verification before TDS credit is granted in accordance with law, while the remaining rectification claims do not survive.

Duty-free inputs common to finished goods and capital goods may be used for captive manufacture within a 100% Export Oriented Unit where capital goods are accounted for and bonded. Liability arises if those capital goods are cleared outside the unit, or upon debonding or exit from the scheme. The admitted application of this clarification resolved the dispute over inputs used in such manufacture, resulting in quashing of the seizure memoranda and show-cause notice, refund of deposits, and cancellation of the bank guarantee. Interest on the refund remained open for determination in accordance with law.

Tariff rate quota benefits applied to qualifying imports of crude soybean oil, making refund of excess customs duty admissible. The position followed prior rulings concerning the same product and import period, and Revenue did not contest it. The refusal of refund was set aside, and the refund claim was required to be processed in accordance with law within three months.

SAFTA preferential duty exemption applied to Bangladesh-origin garment imports because verified Certificates of Origin were linked to invoices and Bills of Entry, Bangladesh authorities confirmed their validity, and no evidence established intellectual-property infringement. Customs detention and provisional release conditions were therefore unsustainable, requiring release against the assessed Bills of Entry with preferential treatment. Enhanced assessable value based on an undisclosed market enquiry lacked particulars or documentary support and was set aside. Regulation 6(1) of the Handling of Cargo in Customs Areas Regulations, 2009 required complete waiver of demurrage, detention and allied charges because the goods had been unlawfully detained.