Statutory outer limits on condoning delay restrict the First Appellate Authority's jurisdiction in GST registration-cancellation appeals; equitable considerations and fact-specific constitutional orders cannot extend that power. However, where the Department has already restored registrations pursuant to the challenged appellate orders, its challenge may become infructuous because reversing those orders without addressing the consequences of implementation offers no effective relief. Failure or inability to seek revocation through Rule 23, including where the common portal blocks a late application, does not extinguish the independent statutory right to appeal cancellation of GST registration.

Income-tax returns constitute personal information protected from disclosure under the RTI Act unless a larger public interest justifies disclosure. That exception is confined to transparency concerning public authorities and does not cover private financial information lacking a bearing on the public at large. A spouse seeking the other spouse's net taxable income for maintenance proceedings cannot rely on the larger-public-interest exception, because the maintenance forum may require both parties to file income, asset and liability disclosure affidavits. The direction to disclose the taxpayer's income details was therefore set aside, without limiting remedies available before the maintenance forum.

Notional interest on interest-free tenancy security deposits is not taxable merely because deposits were received: absent a contractual right to interest or evidence that rent was suppressed or substituted, no real income accrues. Capital introduced by an identified partner through verified bank accounts cannot be added in the firm's hands merely because the partner's antecedent source remains doubtful, unless the funds are shown to belong to the firm. A cash-deposit addition must exclude amounts already treated as partner capital, while unreconciled balances require cash-book verification. Expenditure disallowance under section 14A requires exempt income in the relevant year; ad hoc business-expense disallowance also fails without identified non-business expenditure or record defects.

Computer resources relating to Indian Bank's Core Banking Solution, Real Time Gross Settlement, Automated Teller Machine Switch and Unified Payments Interface Switch, along with associated dependencies, are designated as protected systems under the Information Technology Act, 2000. Access is restricted to employees, service-provider or vendor personnel, and specified external persons who receive written authorisation from Indian Bank, with third-party access limited to need-based access and other external access granted case by case.

Direct Head Office and overseas-branch expenditure incurred specifically for an Indian branch is deductible when directly attributable and supported by invoices, rather than being treated as general Head Office expenditure subject to the statutory cap. Under the India-France DTAA, branch-to-Head Office interest is not independently taxable where paid by the Indian permanent establishment, treaty tax-rate ceilings exclude separate surcharge and cess, and refund interest is taxed at the treaty rate. Common-cost allocations must be benchmarked by a prescribed transfer-pricing method, not assigned a nil value without examining services, costs and allocation keys. ECB interest already attributed to the permanent establishment must be recomputed without double taxation.

Post-detection surrender of depreciation and amortisation claims arising from dealings with a non-genuine supplier was treated as non-voluntary where survey findings and adverse material had exposed accommodation entries, the original return claimed the expenditure, and no revised return correctly disclosed income. Failure to prove the supplier's existence supported misreporting through suppression of facts and false entries; a surrender to buy peace or avoid litigation after detection did not preclude penalty for under-reported income. A challenge that the penalty notice omitted the specific misreporting clause was rejected because it had not been raised before the assessing or appellate authorities or through grounds before the Tribunal. The penalty was sustained and the appeal dismissed.

Section 54F permits acquisition of a new residential asset within one year before transfer of the original asset and does not require that sale consideration alone fund the purchase. Where the flat is acquired within that period and the investment exceeds the capital gain, housing-loan financing does not disqualify the exemption; the capital-gain addition does not survive. Unexplained cash deposits remain liable to addition where the taxpayer produces no documentary evidence of source, fails to rebut adverse findings, and gives inconsistent explanations.

Rule 10B(3) requires examination of differences that materially affect net profit margins and reasonably accurate comparability adjustments where quantification is possible. Capacity underutilisation and differing customs-duty burdens may distort manufacturing-segment profitability, but claims require complete quantitative and documentary support and fresh functional comparability analysis. Regulatory ceilings for external commercial borrowings do not replace transfer-pricing arm's-length benchmarking; interest comparables must reflect materially similar credit profile, scale and risk attributes rather than rely on a single unsuitable comparable. Penalty proceedings for under-reporting, misreporting or alleged false entries remain separate from assessment proceedings, making a challenge to their initiation premature.

Cost-to-cost recovery of salary and travel expenses for employees temporarily seconded to associated enterprises constitutes expense reimbursement rather than consideration for margin-bearing services where recovered exactly at cost. Accordingly, the transfer-pricing mark-up adjustment was deleted, supported by consistent treatment in other years and a bilateral Advance Pricing Agreement allowing recovery at cost. Amalgamation expenditure incurred after approval is amortised over five years beginning in the assessment year relevant to the year of expenditure, not the appointed amalgamation date. The fifth annual deduction was allowed because the claim had been accepted for the prior four years without changed facts.

TNMM functional comparability requires reliable evidence of the proposed comparable's activities during the relevant year. Entity-level margins of a diversified provider cannot support comparison with software development services where undated website descriptions and financial records do not establish segmental revenue or results; the comparable was excluded and the adjustment required recomputation, subject to the safe-harbour limit. Comparable margins must also be recomputed in line with DRP directions. For delayed foreign-currency receivables, arm's length interest cannot be fixed mechanically at a standard LIBOR spread; it requires analysis of the transaction, the associated enterprise's creditworthiness, and comparable uncontrolled rates. Domestic associated-enterprise receivables require verification before interest adjustment.

Closely linked technical know-how fee and poultry feed premix purchase transactions may be aggregated for transfer-pricing purposes under Rules 10AD(d) and 10B. Where know-how fees are netted against premix purchase costs and the associated enterprise's invoice prices are accepted under the CUP method, the resulting reduction in net purchase cost supports arm's length treatment; the separate adjustment for know-how fees was deleted. Related-party performance incentives to directors cannot be disallowed merely because of the relationship. Disallowance requires material showing that expenditure is excessive or unreasonable against fair market value, legitimate business needs, or benefits derived. In the absence of findings or comparables, the incentive provision disallowance was deleted.

Prior-period expenditure is allowable where the liability, including its particulars and quantum, became known and ascertainable only in the relevant year; invoices may be recorded on crystallisation notwithstanding that the underlying expenditure relates to an earlier period. Transfer-pricing analysis must separately benchmark functionally distinct consulting and captive back-office divisions where their functions, methods and economic profiles differ. Entity-level aggregation is unsustainable in those circumstances, supporting deletion of the related adjustment.

Computer resources supporting hospital, laboratory, imaging and blood bank management systems, along with associated dependencies, are declared protected systems as Critical Information Infrastructure. Access is confined to designated employees authorised in writing, authorised contractual managed service provider or third-party vendor personnel requiring need-based access, and consultants, regulators, Government officials, auditors and stakeholders authorised in writing on a case-by-case basis. The designation takes effect upon publication in the Official Gazette.

Manufacturing scrap generated in the ordinary manufacturing process and directly connected with goods produced by eligible undertakings qualifies for profit-linked deduction. Additional exempt-income expenditure cannot be disallowed through a mechanical formula without recorded dissatisfaction, having regard to the accounts, with the voluntary disallowance; no further disallowance was warranted where it exceeded exempt dividend income. Corporate guarantees to associated enterprises are international transactions, with guarantee commission restricted to 0.35% under consistent prior-year treatment; consistency also precluded notional interest on unchanged equity contributions. Common-expense allocation under an established incremental approac.....

Settlement under the Direct Tax Vivad Se Vishwas Scheme, 2020 was confined to the dispute from the original assessment, as confirmed by the declaration, Form No. 5 and Assessing Officer verification. Subsequently initiated reassessment proceedings did not fall within that settlement, so dismissal on the premise that the reassessment dispute stood settled was set aside. The reassessment addition for alleged bogus purchases was deleted because the identities of suppliers, transaction-wise details, invoices and supporting material were not disclosed, leaving no clear factual basis for the addition.

Arm's-length benchmarking of business-support and general-management services rendered to an associated enterprise must focus on the specific controlled transaction and the functions performed, assets employed and risks assumed. TNMM does not remove the requirement for functional comparability; hospital or healthcare entities cannot be selected merely because the taxpayer operates fertility clinics without demonstrating similarity to the services benchmarked. Inadequate examination or production of the agreement, invoices and contemporaneous evidence concerning actual service rendition required fresh determination. The transfer-pricing adjustment was set aside and remitted for arm's-length price determination after FAR analysis and selection of functionally comparable entities.

Omission of clause (i) of section 92BA rendered transfer-pricing references and consequential adjustments for covered specified domestic transactions unsustainable, making the alternative dispute over the most appropriate method academic. Mark-to-market losses from equity and currency futures remained allowable because no material factual or legal distinction from the earlier decision was established. Where audited statements showed own funds exceeded investments generating exempt income, no interest disallowance applied. Administrative expenditure disallowance was confined to investments relevant to exempt income after crediting the taxpayer's self-disallowance. The Revenue's appeals were dismissed, while the taxpayer's alternate challenge did not survive.

Advance Pricing Agreement methodology may guide transfer-pricing benchmarking for an assessment year outside the agreement's term if the FAR analysis and underlying activities do not materially differ from covered years. Where Revenue challenges reliance on that methodology, it must establish the relevant factual distinction. A Transfer Pricing Officer who rejects the taxpayer's benchmarking in favour of the Other Method should apply that method and determine an arm's length price, rather than fixing a nil price on an ad hoc basis.

Unutilised MAT credit and taxes of amalgamating companies may accrue to the transferee where a sanctioned amalgamation scheme so provides. The limited exclusion under section 115JAA for conversion of a private or unlisted public company into an LLP does not extend by implication to amalgamation. Absence of an express enabling provision for amalgamation therefore does not itself prevent succession to MAT credit. The claimed credit remains subject to verification of its quantum and availability under law, with related refund, demand, and interest requiring consequential recomputation.

Advertisement and publicity expenditure paid to third-party vendors does not constitute a separate international transaction of brand-promotion services merely because group communication standards exist or an associated enterprise obtains an incidental benefit; an underlying arrangement or understanding must be established. The related transfer-pricing adjustment was deleted. Where an assessment order and computation sheet show differing carry-forward loss figures, the eligible loss requires verification against assessed income or loss and applicable law; limited recomputation was remanded. TDS/TCS credit after amalgamation depends on the transferee offering or being assessed on the corresponding income, subject to verification of amalgamation records, tax credit and supporting evidence; that claim was remanded.