Condonation of delay under Section 5 of the Limitation Act requires a satisfactory, pleaded explanation establishing sufficient cause. Earlier filing before a court without territorial jurisdiction and administrative movement of records do not, by themselves, justify prolonged delay. A COVID-19 ground not pleaded in the supporting affidavit cannot support condonation. Negligence, inaction, and lack of bona fides are inconsistent with sufficient cause.

Pending reassessment proceedings initiated under Sections 148A(3) and 148 were not examined on merits in writ jurisdiction because the impugned order was only a prima facie determination capable of reconsideration on material furnished during the proceedings. Statutory remedies would remain available if an adverse order followed, while the objection concerning prior sanction remained open before the competent authority. The writ petition was disposed of with all contentions left open.

Deemed timely payment under the Income Declaration Scheme applies where payment by cheque, RTGS or electronic transfer was tendered by 03.10.2017 and credited by the bank by 05.10.2017, treating it as paid by the 30.09.2017 due date. Eligibility for this benefit depends on verification of the cheque tender date and bank credit date. The authority must verify those factual prerequisites and extend the Scheme's benefit if the circular's conditions are met.

Reassessment for AY 2020-21 cannot be initiated solely from information about a land-sale transaction completed in FY 2020-21, because that transaction pertains to AY 2021-22. Where the recorded information, the order under section 148A(3), and the Revenue's affidavit identify the transaction as occurring in FY 2020-21, they provide no basis to infer escaped income for AY 2020-21. The statutory precondition for reopening is therefore absent, rendering the reassessment proceedings invalid and liable to be quashed.

Reassessment proceedings under Sections 147, 148 and 148A require meaningful consideration of an assessee's explanation of bank credits before determining whether reassessment is warranted. Where credits are claimed to include advances and the assessee provides entity details while offering further confirmations and supporting particulars, the tax authority must afford an opportunity to furnish that material. Proceeding without seeking or considering the offered confirmations and clarifications does not adequately assess the fitness of the matter for reassessment.

CBDT instructions and office memoranda standardise recovery or refund adjustment at 20% of the disputed demand as the condition for stay while a first appeal remains pending. Where aggregate payments and refund adjustments exceed that threshold despite a pending appeal, stay application and stay order, recovery must be confined to 20%. Amounts recovered or adjusted above that limit require refund, with the identified excess directed to be returned within four weeks.

Time-bound directions require consequential orders to be passed following appellate decisions, with separate timelines based on whether the available period had expired, was due to expire, or remained available. Interim protection against recovery of the credited refund continues pending further adjudication. The limitation objection concerning consequential orders already alleged to be time-barred, and the related claim that refund should follow the returned income, remain open without final determination. The refund-recovery challenge is also pending further hearing.

Reassessment initiated more than four years after a completed scrutiny assessment requires the taxpayer's failure to file a return or to make full and true disclosure of material facts. Where a discrepancy between TDS-certificate receipts and profit-and-loss-account receipts was specifically queried and answered during the original assessment, no failure of disclosure arises. Reopening solely through reappraisal of already examined material, without fresh tangible material, constitutes an impermissible change of opinion and lacks statutory jurisdiction.

TNMM comparability requires a factual, data-driven assessment of functional similarity under the Income-tax Rules. Companies owning significant intangibles, earning substantial software-product revenue, undertaking product development or product-design services, or deriving income from licences and subscriptions are functionally dissimilar to a captive software development service provider. A standard departmental comparable set cannot replace an assessment of actual functional comparability. As no perversity arose in the Tribunal's factual findings, the exclusion of those companies from the comparability set was upheld in favour of the assessee.

A declaration treating an income-tax return as invalid under Section 139(9) has the character of an authoritative direction and constitutes an order for revision under Section 264. The contrary position that a Centralised Processing Centre intimation invalidating a return is not revisable is legally unsustainable. Revision under Section 264 is therefore available against a declaration that invalidates a return of income.

Revision of an issue outside the scope of reassessment is time-barred where the limitation period for revision runs from the original assessment order. Reassessment initiated for specified financial transactions did not encompass the debenture redemption reserve, which had already been addressed in the original assessment. Section 147, including Explanation 3, permits assessment of another escaped-income issue that comes to notice during reassessment, but no material established that the reserve issue arose in those proceedings. The original assessment therefore remained operative for that issue, and revision concerning the reserve was barred by limitation.

CBDT instructions on stay and recovery of disputed demands before the first appellate authority ordinarily limit recovery to 20% of the demand, with the balance stayed pending appeal. This limitation applies equally to penalty demands and assessment demands because the instructions draw no distinction between them. Refunds relating to other assessment years cannot be adjusted in full against a disputed penalty demand while first appeals and stay applications remain pending. Any adjustment exceeding the prescribed recovery extent must be reversed and refunded with applicable interest, while the balance demand remains stayed until disposal of the appeal.

Section 260A permits an appeal only on substantial questions arising from the ITAT order under challenge. Questions concerning deduction for product development expenditure related to a separate assessee appeal, for which the Revenue had filed an independent appeal, rather than the challenged Revenue appeal. They therefore could not be advanced as substantial questions in the present appeal.

Faceless best-judgment assessments under the Income-tax Act must comply with natural justice by objectively considering material available before completion and affording a reasonable hearing. Expiry of a stipulated response period, without a timely adjournment request, does not itself prevent the Assessing Officer from proceeding; however, the right to reply remains material unless formally closed. Where a response to an extensive questionnaire was filed late but viewed before assessment, it must be considered. A video-conference hearing must be provided before the assessment is redetermined, without addressing the merits of the taxpayer's claims.

Customised road-restoration services supplied by a government authority to enable a business pipeline project are treated as taxable supplies where charges are paid for specific restoration work. The reciprocal, request-driven arrangement distinguishes the charges from compensatory damages and sovereign public-welfare functions, preventing non-supply treatment or exemption; GST falls on the business recipient under reverse charge. Electronic GST portal records can establish the authenticity and integrity of refund proceedings. A notice identifying the factual and legal basis for refund rejection is not invalid merely because no physical Document Identification Number appears, where the recipient responds fully and suffers no prejudice.

Section 129(1)(a) permits detention and penalty where goods are transported in contravention of GST requirements, without requiring proof of intent to evade tax. The obligation is civil and statutory. Rule 138(10) allows an e-way bill's validity to be extended within the prescribed period; failure to obtain an extension leaves transport after expiry non-compliant. Where the vehicle remained in transit nearly three days after expiry, unsupported GPS material and unreliable repair records did not establish a credible breakdown. Circular No. 64 did not exempt transport under an expired e-way bill from Section 129 proceedings.

Refund of accumulated Compensation Cess input tax credit requires independent satisfaction of the statutory refund conditions. Credit accumulated from Compensation Cess paid on coal used in manufacturing leather products for domestic supply does not qualify merely because no Compensation Cess applies to the outward supply; the inverted tax structure category requires accumulation because input tax rates exceed output tax rates. Entitlement to avail credit and restricted utilisation solely for Compensation Cess payments do not create a cash-refund right. The refund formula applies only after substantive eligibility is established. Circular guidance on cess credit for zero-rated supplies under bond or LUT does not extend an unconditional refund entitlement to domestic outward supplies.

Refund of accumulated Compensation Cess input tax credit under the inverted tax structure requires independent satisfaction of the statutory conditions in Section 54(3). Credit eligibility and an inability to use Compensation Cess credit against other tax liabilities do not, by themselves, create a cash-refund entitlement. The restriction limiting use of such credit to payment of Compensation Cess does not remove the need to establish a qualifying refund category. Rule 89(5) provides a computation mechanism only after substantive eligibility is established. Circulars concerning Compensation Cess refunds for zero-rated supplies, including supplies under bond or letter of undertaking, do not extend an unconditional refund right to domestic supplies not subject to Compensation Cess.

Reliable contemporaneous documentation and verifiable transaction parties are required to establish that goods in transit form part of a genuine out-of-State consignment. Delayed invoices and bilties not produced at interception, not reliably linked to undeclared goods, or unexplained by corroborative material do not substantiate lawful documentation. Claimed interstate movement also fails where alleged buyers and sellers do not acknowledge the transaction or establish their identity, business credentials, addresses, ownership, or connection with the consignment. A transit-state principle applicable to documented consignments involving identifiable genuine parties does not extend to unsupported destination claims, supporting penalty action for undeclared goods.

Refund of unutilised Compensation Cess input tax credit requires independent satisfaction of statutory refund categories, including the inverted tax structure. Entitlement to take input tax credit and the restriction that Compensation Cess credit may be used only to pay Compensation Cess do not themselves create a cash-refund right. Non-levy of Compensation Cess on domestic outward supplies or inability to set off the credit against other GST liabilities is insufficient. The cited circulars cover Compensation Cess credit attributable to qualifying zero-rated supplies and do not extend an unconditional refund facility to domestic supplies. Rule 89(5) applies only after substantive refund eligibility is established.