Cash-deposit addition in an income-tax assessment required consideration of the taxpayer's explanation that deposits arose from prior withdrawals and past savings. The explanation was partially substantiated, and an allowance for past savings was considered warranted. The addition was consequently restricted to the supported extent, while the remaining balance was deleted in full.

Section 69B unexplained-investment additions cannot rest solely on an estimated construction valuation where the recorded investment appears in books of account that have not been rejected and no material establishes actual excess cash investment. In those circumstances, reliance on a valuation reference for making the addition is impermissible. Self-supervision allowance in construction valuation must be computed on the gross valuation rather than only on the differential amount. These principles limit valuation-based additions to situations supported by evidence beyond estimation.

Penalty under Section 271C was not sustainable where a materially incorrect loss disclosure could plausibly be attributed to clerical error. The substantial difference between the disclosed and actual losses supported that possibility, rather than establishing a basis for penalty. The penalty was therefore deleted in favour of the assessee on the stated facts.

Statutorily mandated contributions earmarked for accumulation, with only the interest available for welfare objects, have the capital character required for corpus treatment. Restrictions preventing use of the principal for the trust's objects provide the specific direction necessary to treat the receipts as corpus. Such contributions are not assessable as income. Further, Section 12(1) covers voluntary contributions; if the contributions are non-voluntary, they independently fall outside that provision's scope. The resulting addition is deleted.

Income surrendered during a survey for unrecorded loans to debtors and excess cash, when entered in the regular books before the return is filed and offered to tax, remains business income where it arises from the taxpayer's grain, oilseed and pulses trading activities. In the absence of material showing an independent source of income, the unexplained investment and money provisions do not apply. Consequently, the special tax rate for such unexplained income is inapplicable, and the disclosed additional income is taxable at normal business-income rates.

Alleged bogus purchases and unrecorded sales receipts require fresh verification where the taxpayer seeks to substantiate reconciliations and supporting material. The admitted bogus input-tax-credit claim does not remove the need to examine explanations concerning purchases, sales receipts, and documents placed on record. Fresh consideration by the Assessing Officer is required after providing a reasonable opportunity of hearing, so that the reconciliation and supporting evidence can be properly evaluated.

Higher-rate taxation under Section 115BBE requires establishing that income voluntarily declared in a search-assessment return is unexplained or undisclosed income. A declaration alone, without incriminating material or a separate addition, does not satisfy that requirement where the income is stated to arise from regular business. In those circumstances, the declared income is assessable at the regular tax rate rather than the higher rate under Section 115BBE.

Section 153D requires prior approval for each assessee and each assessment year after examination of the relevant draft assessment order and material. A single consolidated approval for multiple assessees and assessment years, without discernible separate consideration, does not satisfy that requirement and demonstrates lack of independent application of mind. Approval is not an administrative formality; a mechanically granted consolidated approval is invalid, vitiates the assumption of jurisdiction, and renders the resulting assessment orders liable to be quashed.

Transfer-pricing benchmarking under the transactional net margin method requires economically and functionally comparable entities. Material turnover differences can affect market position, bargaining power, economies of scale, brand advantage, capacity for complex contracts and profitability; high-turnover and functionally dissimilar entities should therefore be excluded when benchmarking captive software development services. Interest on overdue associated-enterprise receivables must reflect the actual credit risk. Where no basis supports a higher spread and the holding-company receivable presents limited credit risk, LIBOR plus 200 basis points is an appropriate benchmark. The arm's-length price requires recomputation on these bases.

CSR-related donations disallowed as business expenditure under Explanation 2 to section 37(1) may nevertheless qualify independently for deduction under section 80G, provided its conditions are met. Adding back the CSR outlay under section 37(1) prevents double deduction, while mandatory CSR spending does not prevent a payment from being treated as a donation where no quid pro quo exists. Revisionary jurisdiction under section 263 requires both demonstrable error and prejudice to the Revenue. It is not available merely because another view is possible where the assessment record shows enquiry into donation receipts, supporting evidence, payment mode and computation, and the deduction is legally sustainable.

For assessment years beginning before 1 April 2021, the first proviso to section 149(1)(b) permits a notice under the new reassessment regime only if reassessment remained within the erstwhile limitation period when the notice was issued. The extended limitation period under the new regime cannot revive a reassessment power already time-barred. For Assessment Year 2016-17, the former six-year period expired before the June 2024 notice, rendering it time-barred and legally invalid.

Proper officers should accept complete GST registration cancellation applications within 30 days, except where mandatory particulars are missing or a successor entity in a transfer, merger or amalgamation is unregistered. Cancellation takes effect from the date sought, but not before the application date. Applicants must receive written discrepancy details, seven working days to respond, and an opportunity of hearing before rejection. Cancellation does not discharge existing liabilities, and the final return remains mandatory. Closing-stock tax liability may be discharged with the final return, with any shortfall paid in cash.

Refund claim for Assessment Year 1999-2000 must be considered by the assessing authority after the petitioner furnishes the revised return and indemnity bond. The petitioner may submit those details, and the assessing authority must hear the petitioner before deciding the refund claim. The matter was listed for a further date.

Clause (i) of Explanation 1 to section 115JB requires a provision for diminution in the value of an asset to be added back to net profit for book-profit computation. The Schedule VI definition of "provision" covers amounts written off or retained for asset diminution; therefore, a provision for doubtful debts remains such a provision even when shown as a reduction from sundry debtors on the asset side of the balance sheet. Principles governing an actual write-off for ordinary deduction purposes do not apply to this distinct computation. Failure to examine the required add-back may render an assessment erroneous and prejudicial to Revenue, permitting revision under section 263.

Reassessment under sections 147 and 148 requires tangible material with a live link to income escaping assessment in the relevant year. Findings from subsequent assessment years cannot be mechanically applied where the relevant year lacked global-deal agreements, related revenue transfers, and the Hyderabad unit. Material discovered during an ongoing assessment for a later year was distinguishable. Recorded reasons founded on later-year facts amounted to a reason to suspect rather than a reason to believe; the reassessment and consequential assessment were invalidated.

Eligible active registered recipients meeting the applicable aggregate annual turnover threshold may report recipient-generated self-invoices for specified reverse-charge domestic supplies from unregistered persons and imports of services. RCMDOM and RCMIMP must be selected as the relevant e-invoice supply types when reporting through an authorised Invoice Registration Portal. Submission and validation of prescribed invoice particulars would generate an Invoice Reference Number, subject to applicable GST provisions, notifications and e-invoice specifications.

GST exemption applies to services supplied by entities registered under section 12AA of the Income-tax Act for advancement of religion, spirituality or yoga. Residential programme fees covering boarding and lodging are exempt where such advancement is the primary and predominant purpose. Accommodation or food and drinks supplied merely or primarily for consideration, including donations, are taxable, as are fitness camps and classes in aerobics, dance or music.

Punjab GST revises FORM GST RFD-01 refund statements for inverted-duty input tax credit, exports, SEZ supplies, deemed exports and place-of-supply tax adjustments. FORM GSTR-9 introduces reporting guidance and optional simplified disclosures for specified earlier financial years, including consolidated reporting of supplies, input tax credit and reversals. It also permits signed PDF uploads for specified input tax credit reconciliation details in FORM GSTR-9C without chartered accountant certification. FORM GSTR-9C provides optional non-filing of designated reconciliation tables and revised alternative auditor-certification formats.

GST practitioner enrolment applications in FORM GST PCT-1 may be approved or rejected for State enrolment by the Assistant Commissioner or Deputy Commissioner having jurisdiction over the applicant's declared address. Applicants may select either the Centre or the State as the enrolling authority and must record that choice in Item 1 of Part B of the form.

Provision for bad and doubtful debts, when simultaneously reduced from the corresponding debtors or advances under a regular accounting policy, constitutes a write-off rather than a mere provision for an unascertained liability. Where the accounts and resultant book profits have been finalised and adopted, such a write-off is allowable in computing book profits and need not be added back. A concern regarding possible double deduction does not justify an adjustment where that issue did not arise from the underlying proceedings.