Reassessment based solely on transfer-pricing material already examined in scrutiny proceedings is impermissible where the earlier assessment lapsed because no final order followed the draft assessment order within the prescribed period. Without fresh material, reopening would circumvent the statutory time limit for completing assessment and allow the Revenue to benefit from its own omission. The reassessment notices and the order under section 148A(3) were quashed, and the writ petition was allowed.

Common appellate remand orders must address year-specific findings where the record contains a reasoned appellate decision on the same issues. Restoring Assessment Years 2012-13 and 2013-14 solely by applying the finding for the earlier year, without examining the detailed reasoning for 2013-14, amounted to non-application of mind. Because the material, appeal grounds and cross-objections were before the Tribunal, merits required adjudication rather than a mechanical remand. The common remand order was quashed, and both appeals were returned for fresh determination on merits after hearing the parties.

Inadequate supporting evidence for a house property loss and deductions under sections 80C and 80D led to scrutiny of their substantiation. Where the documents were partly self-serving and unreliable, the aggregate disallowance was replaced with an ad hoc addition equal to 10% of the disputed claims. The addition was taxable at normal rates rather than under section 115BBE. The appeal was partly allowed by limiting the addition to that estimated amount.

Unsigned third-party excel sheets and ledger material, lacking purchaser or seller signatures and independent corroboration, cannot by themselves establish an alleged on-money payment for a commercial unit. Reliance on such material without allowing cross-examination of the third party breaches principles of natural justice. No change in facts or law, and no contrary material from Revenue, warranted departure from the coordinate decision; the addition for alleged on-money payment was deleted and the appeal allowed.

Penalty notice expressly stating that underreporting resulted from misreporting discloses the Assessing Officer's satisfaction and is not vague. Income omitted from the return despite being admitted during a survey may constitute underreported income when assessed income exceeds income processed under section 143(1). Enhanced penalty for misreporting requires proof that the conduct falls within a specified instance of misreporting under section 270A(9); merely applying the enhanced rate is insufficient. The penalty was therefore confined to 50% of tax on underreported income.

Limitation for filing an appeal may be relaxed only upon a bona fide and reasonable explanation establishing sufficient cause. After allowing the COVID-19 extension of limitation, expectations of a favourable consequential assessment, later professional advice, and family circumstances did not explain the remaining delay. Continued representation through qualified professionals and participation in consequential proceedings indicated a later change of position following an adverse consequential assessment. The delay was therefore not condoned.

Gross principal cash movements routed through an Angadia network were not taxable as the assessee's unexplained money where the accepted business model showed only a facilitation role and no material established ownership of the funds or corresponding asset accretion. Applying the real-income principle, taxability was confined to embedded commission income, resulting in rejection of the Revenue's challenge to deletion of principal additions. Commission on unaccounted turnover was estimated at 0.30%, rather than 2%, after credit for commission already assessed, because of the business's low-margin nature. The commission income was taxable at normal rates rather than under section 115BBE.

Carried-forward loss from scientific research expenditure remains examinable in the year in which set-off is claimed, and its earlier computation does not conclusively determine its character or eligibility. Where concessional corporate taxation is elected and the additional weighted deduction is forgone, the underlying actual scientific research expenditure may still be considered under otherwise applicable provisions. Restrictions on specified incentives and exemptions do not, without an express prohibition, deny actual expenditure independently allowable under law. Allowance of the corresponding carried-forward loss requires verification of the underlying expenditure and consequential recomputation, without granting the additional weighted deduction.

Eligibility for India-Mauritius DTAA capital-gains benefit on redemption of equity-oriented mutual fund units requires factual verification of commercial substance and surrounding circumstances; documents need not be accepted at face value where their apparent position may not reflect reality. Information relating to a management shareholder's licence and regulatory action involving a sister concern requires fresh examination after an effective and adequate opportunity to explain. Taxability of the gains was restored for fresh determination of treaty-benefit eligibility, without a merits determination.

Foreign tax credit under section 90 for United States tax paid on salary and interest income requires timely filing of the income-tax return and Form 67, supported by proof of foreign tax payment. Compliance with these prescribed formalities supports entitlement to treaty-based credit and grant of the claim where the required conditions are met.

Related-party transaction filtering for Ideavate Solutions excludes key managerial personnel remuneration; it therefore qualifies for inclusion among software development comparables. Toxsl Technologies is functionally comparable on annual-report analysis and is included. The functional comparability of Great Software Laboratory, Consilient Technologies, Systango Technologies and Ksolves India requires reassessment against prior Tribunal decisions, with exclusion where the taxpayer's claim is substantiated. Working-capital-adjusted margins require verification, and appropriate transfer-pricing relief may follow where warranted.

Rupee-denominated non-convertible debentures are treated as debt instruments for the concessional interest-tax treatment contemplated by section 194LD, because statutory definitions encompass interest on money borrowed, debt incurred, debentures and other securities. The bond-debenture distinction does not affect eligibility where the instruments are rupee denominated and the investor satisfies the prescribed foreign portfolio investor and other conditions. A separate claim under section 194LC requires express consideration: where an objection is left unaddressed in the final assessment, a denial attributable to that claim cannot be sustained.

Written acceptance of reassessed customs value does not waive an importer's statutory right to challenge the valuation opinion or reassessment; it only removes the proper officer's obligation to issue a speaking order. Declared transaction value may be rejected only after reasonable doubt is formed and the grounds are communicated in writing under Rule 12(2). Undisclosed contemporaneous-import particulars and NIDB data, without independent cogent material, cannot sustain value enhancement. The enhanced valuation and the order affirming it were set aside, with consequential relief in accordance with law.

Boiler-specific fabricated support steel structures imported in CKD condition are classified as other boiler parts under CTI 84029090 where their design, drilling, tagging and configured placement objectively establish sole or principal use with a particular boiler. Their load-bearing role and boiler-specific access, inspection and maintenance arrangements support application of Section XVI Note 2(b), while identifiable machinery parts are excluded from Heading 7308. CKD importation does not change the goods' identity. Heading 9406 does not apply because structures supporting and suspending boiler equipment, with operational access, neither constitute nor have the essential character of prefabricated buildings.

Section 477(1) permits summoning persons suspected of holding company property or able to provide information about its affairs. An earlier refusal to summon original directors under another provision did not create res judicata because the statutory power under Section 477(1) had not been considered. The directors were required to disclose by personal affidavits their movable and immovable assets, including post-debenture acquisitions. Technical lag on the e-bidding platform excluded genuine bidders; accepting a single intervening bid could prejudice creditors and debenture holders, so fresh e-bidding for Lot No. 1 was required.

Eligibility for the first proviso to section 45 PMLA depends on the amount a person is accused of laundering alone or jointly with co-accused, rather than funds traced solely to that person's account. A joint accusation exceeding the statutory threshold therefore excluded the proviso's benefit. Under section 45's twin bail conditions, reasonable grounds are assessed on broad probabilities, but the prosecution must first show a scheduled offence, property derived from it, and the accused's knowing involvement in laundering. Documentary material did not sufficiently establish proceeds of crime, collusion, or knowledge; with no alleged prior misuse of liberty and manageable influence concerns, the conditions were satisfied and bail was granted subject to conditions.

Right to speedy trial supported bail in money-laundering proceedings despite the statutory twin conditions where predicate-offence charge-sheets remained unfiled and neither the predicate nor money-laundering trial had a realistic prospect of timely completion. Proceeds of crime under the PMLA must arise from criminal activity relating to a scheduled offence; consequently, final determination of the money-laundering charge depends on establishment of the scheduled offence. The continued unexplained delay constituted a material change from the earlier bail refusal, and constitutional protection of personal liberty under Article 21 justified release on bail subject to conditions.

Original works pertaining to railways, including railway training-school and hostel construction, fall within the service-tax exemption; a de novo authority cannot reopen an exemption or cum-tax valuation benefit left unchallenged and outside the remand scope. Works-contract services for qualifying non-commercial Government, clinical and educational buildings under pre-March 2015 contracts receive retrospective exemption where the recipient is a Governmental Authority, including eligible subcontracted services. Gross receipts are tax-inclusive where tax was not separately collected. A turnover differential requires a factual basis in the notice and record. Nil preceding-year taxable turnover supports threshold exemption. Extended limitation.....

Registration compliance requires bank-account details within 30 days of registration or before filing FORM GSTR-1 or using the invoice furnishing facility, whichever is earlier, and permits risk-based physical verification. Registration must be suspended for material return and supply-data anomalies or failure to furnish bank details, subject to electronic intimation and response. Where FORM GSTR-3B input tax credit exceeds FORM GSTR-2B beyond prescribed parameters, taxpayers must, within seven days, pay the excess credit with interest or provide reasons through FORM GST DRC-01C; unresolved amounts may be pursued through demand and recovery mechanisms.

Pre-packed SIM cards and GSM fixed wireless phones fall within packaged-commodity requirements where supplied without the purchaser being present and at a predetermined value. Transfer of a subscriber's right to use the devices, activation charges, and no commitment to replace lost or damaged devices free of cost may indicate a sale; contractual retention of title does not displace consumer-protection declarations, including price disclosure on the principal display panel. For alleged declaration breaches, non-compliance with a compounding notice leads to proceedings before the jurisdictional Magistrate, preserving the opportunity to raise defences despite the absence of a separate adjudicatory mechanism. The intra-Court appeal succeeded, the quashing order was set aside, and the writ petitions were dismissed.