Accepted sales and unrejected books of account preclude treating the entire value of alleged bogus purchases as non-genuine when those purchases support recorded sales. The taxable addition is confined to the profit element embedded in purchases from non-genuine suppliers. On the stated facts, a 12.5% gross-profit estimate was excessive, and the addition was limited to 5% of the disputed purchases as business income.

Cash deposits during demonetisation recorded in unrejected audited books and supported by verifiable prior bank withdrawals satisfy the source-explanation requirement for unexplained cash credits. Where books are not rejected and bank records substantiate withdrawals and subsequent deposits, the deposits cannot be treated as unexplained income. The enhanced tax rate with surcharge under section 115BBE does not apply for assessment year 2017-18. Accordingly, additions for the cash deposits and their treatment as unexplained income were unsustainable.

Interest awarded under Section 28 of the Land Acquisition Act, 1894, on enhanced compensation for compulsory acquisition of agricultural land bears the character of enhanced compensation rather than separately taxable interest. It forms part of the enhanced value of the acquired land and consequently receives the same exemption under Section 10(37) of the Income-tax Act, 1961 as the underlying compensation.

Section 56(2)(viib) read with Rule 11UA permits valuation of unquoted equity shares using prescribed methods, including the Discounted Cash Flow and Net Asset Value methods. The assessee may choose a prescribed method, while the Assessing Officer may scrutinise the valuation's assumptions, projections, discount rates and other inputs. Past losses or reliance on management projections do not, by themselves, justify replacing a Discounted Cash Flow valuation with the Net Asset Value method. Replacement requires identified arithmetical errors, factual inaccuracies, internal inconsistencies or foundational defects in the chosen valuation. In their absence, substitution of the valuation method is impermissible.

Deletion of the negative working capital adjustment through rectification requires recalculation of the assessee's revised margin to determine whether it remains within the permissible arm's length range. The consequential appeal-effect order must implement the rectification, consider the revised-margin claim, and allow a hearing before reaching a different conclusion. If the revised margin is within the permitted range, no transfer pricing adjustment survives; any grievance against the consequential order may be pursued through revival of the appeal.

Section 127 transfer orders govern all proceedings, including reassessment proceedings initiated after transfer, and divest the transferor Income-tax Officer of jurisdiction. Sections 147 and 148 permit reopening and issuance of a foundational reassessment notice only by the Assessing Officer holding jurisdiction under Section 2(7A) and applicable jurisdictional directions. Administrative PAN-database entries cannot confer or retain jurisdiction contrary to a subsisting statutory transfer order. Consequently, a reassessment notice issued by the former officer, and resulting proceedings, lack legal authority.

Reassessment cannot be initiated solely on unverified Insight portal information suggesting possible income escapement. Verified material must establish a nexus between the assessee and the alleged transaction, and the record must demonstrate application of mind. Where notices and orders disclose no transaction details, attribute identical alleged income to multiple taxpayers, fail to quantify the assessee's alleged benefit, and do not supply or verify the underlying information, reassessment amounts to an impermissible roving and fishing inquiry. Such reassessment initiation is invalid for lack of material linking the assessee to the alleged escaped income.

Income-tax recovery sought through debit notes as a component of electricity tariff involves disputed factual and documentary questions concerning liability. Tariff-related claims, including tax components, fall within the adjudicatory jurisdiction of the Central Electricity Regulatory Commission under the regulatory framework. Such disputes should therefore be raised before the Commission, which can determine liability after hearing all affected parties, rather than pursued through writ jurisdiction.

Belated refund claims may be admitted within the prescribed six-year period where the claim is correct and genuine and refusal would cause genuine hardship. The authority must assess those criteria independently, may verify the claim, and give a reasoned decision based on recorded grounds. A separate sufficient-cause explanation for delay, analogous to the Limitation Act standard, is not an independent requirement under this framework. Factors relevant to hardship include employment loss, the refund sought and final comparable decisions. The framework calls for fresh consideration of condonation without deciding the underlying exemption claim.

Reassessment of an investor cannot rest solely on allegations that a mutual fund manager manipulated accounting methodology. The Assessing Officer must possess information establishing a rational nexus or live link between those allegations and the investor's own escaped income, including material connecting the investor to a sham arrangement or fictitious loss. Where no material showed the investor's knowing participation and binding coordinate precedent governed the identical issue, the reassessment notice under Section 148 and the order under Section 148A(d) were quashed.

Reassessment of the section 80JJAA deduction was impermissible because the original scrutiny assessment had specifically examined eligible additional employees and related costs, received supporting material, and accepted the claim under section 143(3). Reopening under sections 148A and 148 raised the same issue without fresh tangible material unavailable during scrutiny, amounting only to a change of opinion. The section 148 notice and section 148A(d) order were therefore quashed in favour of the assessee.

Ownership established under Benami law does not itself justify release of cash seized in an income-tax search. The first proviso to section 132B(1)(i) permits a third-party claimant to seek release even where assets were seized from another person, subject where necessary to indemnity for competing claims. Release requires an application within the stipulated period and a satisfactory explanation to the Assessing Officer of the nature and source of acquisition. Benami findings that cash is not benami establish ownership only for those proceedings and do not displace the income-tax inquiry into its source. Questions concerning the statutory time limit, non-decision of an application, and deficient applications remain for Larger Bench determination.

Tax deduction on external development charges was in issue: whether the payments constituted rent subject to deduction under section 194-I or contractual payments under section 194C. The Special Leave Petition was not entertained because a 328-day filing delay was not condoned; the reasons offered were found unsatisfactory and insufficient in law. The petition was consequently dismissed without resolving the TDS classification of the charges.

Monetary refunds of unutilised input tax credit exceeding entitlement under the refund formula may be treated as erroneous refunds recoverable under Section 73. Recovery jurisdiction does not require prior reversal of the original refund sanction through departmental appeal or revision, although it does not permit disregard of a subsisting appellate determination. Sections 73 and 50 impose compensatory interest on erroneous refunds, irrespective of fraud, taxpayer fault, or departmental error in granting the refund. The substituted refund formula applied from its stated effective date, while the later interest-computation rule neither created nor removed the underlying statutory interest liability.

Effective service of a rectification notice under Section 161 of the Central Goods and Services Tax Act, 2017 is necessary before rejecting a refund claim. Where the notice is returned undelivered, the affected person lacks a meaningful opportunity to respond to the proposed rectification and participate in the hearing. An earlier written reply and the statutory deadline for passing an order do not replace effective notice or an opportunity to be heard. Adjudication in these circumstances violates the principles of natural justice.

Section 6(2)(b) of the CGST Act applies when central and state departmental proceedings concern the same tax liability, deficiency or obligation arising from a particular contravention; similar liabilities arising from distinct infractions do not trigger the bar. State GST proceedings had already covered FYs 2017-18 and 2018-19, while the central authority confirmed a consolidated demand extending from July 2017 to November 2022 and including those years. The consolidated demand could not cover the overlapping financial years. The impugned order was quashed and remitted for fresh determination excluding FYs 2017-18 and 2018-19.

GST registration cancellation requires a clear show cause notice and a meaningful opportunity to furnish supporting evidence before retrospective cancellation. A registrant's request for reasonable time to produce purchase and sale records, e-way bills and transport evidence must be addressed. Revocation or appellate action cannot rely on allegations absent from the original notice, including unnotified input tax credit concerns. Registration-cancellation proceedings and separate tax-demand proceedings for fraudulent input tax credit availment or suppression operate in distinct statutory domains and cannot be conflated. Fresh action requires an appropriate notice, proper hearing and opportunity to produce evidence.

Condonation of delay in seeking revocation of cancelled GST registration requires examination of the justification for delay and a meaningful opportunity of personal hearing. Rejecting the condonation application before the scheduled hearing, while deciding the merits of the underlying revocation request, exceeded the scope of the proceeding. Appellate review of the delay-condonation issue likewise could not determine the revocation application on merits. The rejection order, appellate order and show-cause notice were quashed, with fresh proceedings required in accordance with law.

Statutory appellate remedies generally preclude GST writ jurisdiction where challenges to an adjudication order require examination of disputed facts. Allegations that replies were not considered and that no role was attributed to particular persons required assessment of replies, transaction roles, accounts, invoices and allegedly ineligible input tax credit by the Appellate Authority. Writ intervention was therefore inappropriate. The speaking-order principle did not require a different result because the adjudication was a common, extensive order involving multiple firms and individuals, unlike a decision concerning an individual assessee.

GST adjudication under Section 73 requires observance of natural justice, including effective intimation of the adjudication order, a meaningful opportunity of hearing, consideration of the taxpayer's reply, and a reasoned determination. Uploading an order only in the portal's "Additional Notice and Orders" tab, without separate intimation, may not provide an effective hearing. Where these safeguards are absent, fresh adjudication is required after properly considering the reply and affording a hearing.