Section 10A deduction computation requires every item excluded from export turnover to be excluded correspondingly from total turnover, preserving parity in the statutory formula. The deduction is undertaking-specific and must be computed before setting off losses of one eligible unit against profits of another. Transfer-pricing comparable selection requires functional, asset and risk analysis; a high-scale branded knowledge-process-outsourcing provider with significant intangibles is unsuitable for comparison with a captive contact-centre service provider, while unresolved comparable objections require factual adjudication. Capitalised software expenditure may qualify for depreciation where prior capitalisation and depreciation treatment are verified. Claimed exclusions of specified expenses require verification.

Cash deposits in a taxpayer's bank account were claimed to arise from agricultural land sale proceeds, past savings and accumulated agricultural income. Supporting affidavits from ten family members formed part of the evidentiary material. On the stated facts and circumstances, a limited addition was retained, while the balance addition was deleted.

Penalty for under-reporting attributable to misreporting under section 270A(8) cannot be sustained merely because a deduction under section 80P was claimed on interest from cooperative banks or societies. Coordinate-bench decisions supported the availability of that deduction, making the quantum disallowance a debatable legal claim. Mere assertion of a debatable claim does not by itself establish misreporting. On that basis, the section 270A(8) penalty was deleted in favour of the assessee.

Transfer-pricing analysis under Rule 10B(3) requires reasonably accurate adjustments for material differences affecting comparability. Capacity underutilisation may warrant an adjustment for excess depreciation where the depreciation-to-sales ratio reliably measures the absorption of fixed depreciation costs through production and sales; a lower ratio indicates more effective capacity use. Reducing excess depreciation recalibrates the tested party's operating-profit-to-operating-cost margin. Where the adjusted margin falls within the arm's-length range, objections to selected comparables may cease to affect the analysis.

Section 250(6) of the Income-tax Act, 1961 requires the appellate authority to formulate points for determination and provide reasoned adjudication. Failure to meet these requirements, particularly where virtual-hearing communication gaps may have prevented proper representation, deprives the taxpayer of effective appellate consideration. An appellate order lacking stated points and reasoned findings should be set aside and restored for fresh adjudication after effective hearing opportunities are provided.

Section 69C applies only where the source of expenditure remains unexplained. Construction-related purchases recorded in audited books, supported by material explaining their source, do not constitute unexplained expenditure merely on presumption. An addition requires enquiry establishing that the expenditure was unaccounted for; unsupported assumptions without verification cannot sustain it. Accordingly, the proposed addition for unexplained expenditure is not sustainable where the recorded expenditure and its source are corroborated.

Rectification for a mistake apparent from the record is confined to patent errors and cannot displace directions justified by unverified evidence or incomplete factual examination. An affidavit relied on in a penalty matter required verification by the Assessing Officer under Rule 46A, supporting restoration for fresh adjudication. Cash-receipt material without distributor confirmations, coupled with uniform receipt patterns, also required further factual examination. An earnest-money deposit received for distributorship was not a sale receipt and therefore fell outside the cash-receipt restriction. No apparent mistake warranted rectification of the fresh-adjudication directions.

Withdrawal of a deduction under Section 80GGC in a return filed after reopening creates under-reported income where reassessed income exceeds the prior processing, notwithstanding acceptance of the later return. A withdrawal made merely to buy peace does not establish a bona fide claim supported by material facts and therefore does not fall within the statutory exclusion. Misrepresentation or suppression of facts attracts the enhanced penalty for misreporting. A penalty charge is adequately specified where the assessment records the applicable misreporting ground and the notice refers to that assessment finding. Voluntary withdrawal and a notice objection do not displace liability where those requirements are met.

For Section 54F deduction, adjoining flats acquired under separate sale deeds may constitute one residential house where they function as a single composite dwelling. Separate flat numbers, sale deeds, tax-deduction entries, and database records do not conclusively establish independent residential houses. Where adjoining newly acquired units are used as one residence, they satisfy the requirement of investment in one residential house. Similarly, existing adjoining flats used as a single dwelling do not amount to ownership of more than one residential house under the proviso. On unrebutted evidence of composite residential use, the Section 54F deduction is allowable.

Section 54F can treat two separately registered flats as one residential house where their substance and functional character establish a single family residence. The provision does not require residential accommodation to be one physical unit, located on one floor, or acquired through one registered instrument. Simultaneous purchase from the same developer in the same building and wing, coupled with intended combined residential use, supports treatment as one residential house. Deduction under section 54F is consequently available for investment in both flats.

Reassessment proceedings require recorded reasons for reopening to be furnished when requested after the assessee files a return in response to the reopening notice. The assessee must then have an opportunity to raise objections, which must be disposed of through a speaking order. Failure to formally communicate the recorded reasons is a mandatory jurisdictional defect; presumed awareness from earlier proceedings or assessment questionnaires cannot cure that non-compliance. Reassessment undertaken without these safeguards is invalid and liable to be quashed.

Under section 153A, the six assessment years are those immediately preceding the assessment year relevant to the previous year of search, excluding the search assessment year. In contrast, Explanation 1 to section 153A, applied pari materia to section 153C and the limitation framework under section 149, calculates the ten-year period from the end of the assessment year relevant to the search year. The search assessment year therefore forms the first year of that ten-year block. For a search during FY 2024-25, AY 2015-16 falls outside the prescribed period, making a section 148 notice time-barred.

GST adjudication requires verified findings based on statutory returns, reconciliations, books of account and other relevant records. Excess input tax credit claims require scrutiny of GSTR-9, GSTR-9C and statutory disclosures. Manufacturers making taxable and exempt supplies must apportion input tax credit, while traders need not proportionate credit where exempt goods are purchased and supplied without input tax credit. Orders must address taxpayer replies with reasons, contain accurate notice particulars, follow independent verification before issuing notices, provide hearing where required, and avoid recovery while rectification applications remain pending.

Jurisdictional objections to an arbitral tribunal deciding an excepted matter must be raised at the prescribed stages of arbitration. Sections 16(2) and 16(3) require timely objections to jurisdiction or excess of authority, subject only to the tribunal accepting a justified delay. Participation with knowledge of a contractual limitation and without specific objection constitutes deemed waiver under Section 4. Section 34 cannot be used independently to bypass those time limits and waiver consequences, consistently with the policy of minimal judicial intervention under Section 5. The award therefore remained immune from challenge on the excepted-matter objection.

ITC claimed in FORM GSTR-3B but absent from FORM GSTR-2A for FY 2017-18 and 2018-19 must be verified against statutory conditions, including possession of prescribed documents, receipt of supplies, payment to the supplier, supplier tax payment, required reversals, and the time limit for availment. Verification of supplier tax payment depends on a professional certificate for higher per-supplier mismatches and a supplier certificate for lower mismatches. The process is confined to bona fide reporting errors in ongoing or pending proceedings and excludes completed proceedings.

Proper officers must communicate show-cause notices and adjudication orders through physical mode in unregistered assessment proceedings under Section 63 of the OGST Act, 2017. Effective service must be verified to enable the noticee to participate, file objections or explanations, and produce relevant material before adjudication. Physical service is required to avoid ex parte assessment without a meaningful opportunity of hearing and disputes concerning non-service.

Transportation services for goods sent outside India have the foreign destination as their place of supply where both supplier and recipient are located in India. The supply is treated as an inter-State supply and is chargeable to IGST. The Indian recipient may claim input tax credit of the IGST charged, subject to applicable eligibility conditions, apportionment provisions and blocked-credit restrictions. The supplier must report the place of supply in FORM GSTR-1 using State code "96-Foreign Country".

Pre-CIRP GST dues of a corporate debtor are operational debt and cannot be pursued through coercive recovery; the proper officer may file the claim in insolvency proceedings. Where finalised insolvency proceedings reduce confirmed statutory dues, those proceedings are treated as other proceedings for recovery purposes. The jurisdictional Commissioner must issue FORM GST DRC-25 to communicate the reduced demand where FORM GST DRC-07 or DRC-07A was issued. Recovery may continue only for the reduced dues.

Capital-gains tax treatment is queried where land bequeathed to son X was sold after alleged manipulation of title documents. Although title was confirmed in X's favour, the earlier sale to buyer 1 was not declared null and void. Buyer 1 proposes a resale to buyer 2, with X joining as a consenting party and receiving part of the consideration. The issues concern long-term capital gains, partial consideration, application of section 78, and recording payment to X in the sale deed.

GST registration applications must be filed online using the form applicable to the applicant category, with complete and legible identity, business constitution, signatory, premises and other required particulars. Principal and additional business premises require accurate addresses and prescribed ownership, lease, consent, co-working or Special Economic Zone evidence. Aadhaar-authenticated applications generally follow the shorter processing timeline, while non-authenticated or risk-selected cases can require biometric checks or physical verification. Deficiencies must be addressed through the prescribed notice-and-reply process; unnecessary documents and subjective objections are excluded. Simplified registration provides automated processing for eligible small taxpayers subject to input tax credit restrictions.