Transfer-pricing comparability requires valid economic criteria, including uniform application of a ten-times turnover filter; prior inclusion in a taxpayer's study does not prevent a later comparability challenge. Functional comparability requires verification of functions, assets and risks, including relevant filters for disputed companies. Foreign-currency receivables should be benchmarked to the relevant foreign-currency market rate, with LIBOR plus 200 basis points applied instead of domestic rupee rates. Provisions for bad and doubtful debts are not operating costs because they do not represent actual expenditure. Negative working-capital adjustments require examination of working-capital risk and an adequate opportunity to be heard.

Minimum Alternate Tax under section 115JB is inapplicable to a corresponding new bank constituted under the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970. The book-profit computation provision applies only where the second proviso to section 129(1) of the Companies Act, 2013 applies. Such a bank is neither formed nor registered under the Companies Act and is not a banking company for that provision. Its deemed status as an Indian company for Income-tax Act purposes cannot extend to Companies Act status; therefore, book-profit tax cannot be levied.

Section 148A(b) requires a minimum seven-day period for an assessee to respond before a reassessment notice is issued. Allowing only five days breaches the mandatory hearing requirement, creates a substantive jurisdictional defect, and violates principles of natural justice. Participation in assessment proceedings does not cure that defect under sections 292B or 292BB. The section 148A(b) notice, ensuing section 148A(d) order, section 148 notice, and reassessment order were quashed.

Interest income earned by a cooperative society from investments with another cooperative society qualifies for deduction under section 80P(2)(d). Interest on fixed deposits and savings accounts with cooperative banks or scheduled commercial banks is assessable as Income from Other Sources, rather than as income from providing credit facilities to members or investments with another cooperative society; it does not qualify under section 80P(2)(a)(i) or section 80P(2)(d). Administrative or other expenditure connected with earning that taxable interest may be deducted under section 57, subject to verification.

Cash receipts and payments recorded in seized material reflected finance-brokering transactions undertaken for commission rather than balances supporting a peak-credit addition. Where the assessee acted as a broker arranging finance, commission income is to be estimated at 3% of total cash receipts, consistent with the approach applied in earlier assessment years. The cash-flow pattern does not support retaining an addition calculated on peak credit.

Reassessment initiation under the post-1 April 2021 regime must comply with the notified faceless procedure. Notices issued by a jurisdictional Assessing Officer outside that procedure are treated as jurisdictionally defective and liable to be quashed. For notices issued more than three years after the relevant assessment year, Section 151(ii) requires sanction from the Principal Chief Commissioner or Principal Director General; approval solely from a Principal Commissioner is insufficient. Invalid initiation on either ground renders the consequential reassessment void ab initio.

Section 69A requires material demonstrating that the assessee owned or received unrecorded money and that its source was unexplained. Uncorroborated WhatsApp chats concerning alleged Dubai property-sale proceeds, without cash, foreign-currency or banking evidence, third-party confirmation, or a live and proximate nexus to the assessee, cannot alone establish receipt. Where the property is legally owned by a third-party entity, an unexplained-money addition based only on such electronic records rests on conjecture and suspicion. The proposed addition and consequential taxation under Section 115BBE were therefore unsustainable.

Genuine hardship under Section 119(2)(b) requires a liberal assessment of the reasons for delay in filing a return. Pandemic restrictions, reduced staff capacity, limited access to business records and compliance duties at construction sites may constitute material circumstances supporting condonation. Circular No. 09/2015 on belated refund claims and carry-forward of losses did not govern the application. Availability of a deduction under Section 80-IBA could not justify refusing condonation. The refusal to condone the 13-day delay was unsustainable and required reconsideration after addressing the stated hardship factors.

Arms-licensing discretion requires a police report before grant unless the statutory proviso permits action without it after the prescribed period; where no period is prescribed, the authority must allow reasonable time in the circumstances. Prosecution sanction for public servants requires visible, independent application of mind, identifying the material considered and the basis for prima facie satisfaction; generic references to case-diary material are insufficient. The right to speedy trial extends to investigation, including further investigation. Exceptional, unexplained delay requires continuing judicial oversight and recorded justification, and may support relief under applicable inherent-jurisdiction provisions. Invalid sanction and unjustified prolonged investigation make continuation of criminal proceedings untenable.

Section 68 addition for cash deposits in demonetised currency was considered unsustainable where deposits aligned with the business's substantial turnover, wholesale pharmaceutical operations, geographical spread, and collection practices. The maintained cash book had been furnished and no defect was identified. Comparing deposits of old currency notes solely with the cash balance on the relevant demonetisation date was not a justifiable basis for the addition. The addition, representing only a small proportion of total cash deposits, was deleted.

Agricultural income claimed as exempt was not liable to addition as income from other sources merely on an unsupported allegation of duplicate agricultural expenditure. Where ownership of agricultural land, agricultural produce and the income source were undisputed, and the partnership firm's accounts contained neither agricultural income nor agricultural expenses, entries reflecting drawings from the partner's current capital account did not establish a duplicate claim. The addition for alleged double claiming of agricultural expenditure was deleted.

Commission income from accommodation-entry transactions should be estimated consistently where the admitted nature of transactions and material circumstances remain unchanged across assessment years. A 10% estimate lacks a stated basis where subsequent assessments applied a rate of Rs. 2,000 per crore on materially unchanged facts. Applying the rule of consistency supports using that accepted rate for the relevant assessment year rather than a higher percentage-based estimate.

Section 148 notices issued by jurisdictional Assessing Officers, rather than through the faceless reassessment regime, were treated as inconsistent with Section 151A and the applicable notification. Applying the stated jurisdictional precedent and co-ordinate bench approach, invalid initiation of reassessment also defeated the consequential reassessment and related addition. The deletion of the addition was therefore sustained.

Gross GST revenue for September 2026 distinguishes domestic collections and IGST on imports; after domestic and ICEGATE refund adjustments, net revenue is calculated separately for domestic and customs GST. Cumulative collections through September similarly distinguish gross receipts, refunds and net revenue. SGST reporting compares pre-settlement receipts with post-settlement amounts that include the SGST portion of IGST settled to States and Union Territories. State and Union Territory revenue comparisons exclude GST on imported goods, while April-September domestic collections are split between Central and State formations.

TRQ holders allocated quantities for raw sugar imports may surrender unutilised quantities until 15 October 2026. Surrender requires payment of an amount equal to 0.5% of the CIF value of the surrendered quantity under existing modalities. The extension alters only the surrender deadline; all other conditions governing the raw sugar TRQ allocation and surrender framework remain unchanged.

Minimum Import Price condition on imports of Virgin Multi-layer Paper Board under Chapter 48, Schedule I, and ITC (HS) codes 48059100, 48059200, 48059300, 48109200 and 48109900 is extended until 31 March 2027. The MIP remains INR 67,220 per metric tonne on CIF value, while all other terms and conditions under the prior framework remain unchanged.

Project Jagrook requires stock brokers to display investor awareness messages alongside risk disclosures. Between October 5 and October 31, 2026, website display of both is mandatory, while trading-app display of investor awareness messages is voluntary and risk disclosures are optional where such messages are displayed. From November 1, 2026, brokers must place investor awareness messages on website and trading-app landing pages and display investor awareness messages and risk disclosures on alternate days on trading apps. Stock exchanges and depositories must disseminate, display and implement these requirements.

Royalty paid for technical know-how used in manufacturing should be benchmarked under the Transactional Net Margin Method where the foreign associated enterprise only provides technology and does not undertake manufacturing or sales functions. The Profit Split Method requires both associated enterprises to contribute to profits from the relevant transaction and is generally unsuitable without a unique and valuable contribution by the technology provider alongside the manufacturer. On materially similar prior-year and group-company facts, the Transactional Net Margin Method is the most appropriate method; the arm's length price requires recomputation after the taxpayer receives an opportunity of hearing.

ASI 2024-25 records broad-based growth in registered manufacturing, including establishments, output, Gross Value Added, employment, emoluments, fixed capital, invested capital, net income and net profit. The survey covers specified registered factories, bidi and cigar establishments, certain electricity undertakings, and qualifying large units in State-maintained business registers. Data are collected electronically under the statutory framework for collection of statistics using an establishment-based approach, with quality checks and caution required because the estimates arise from a sample survey.

The fifth Kautilya Economic Conclave will examine economic resilience amid global shocks through discussions on macroeconomic stability, monetary policy, financial stability, investment, fiscal federalism and capital-market development. Its agenda also covers digital economy governance, artificial intelligence, trade fragmentation, strategic autonomy, climate resilience, food systems, demographic change and global health security. Plenaries, parallel sessions and closed-door roundtables will consider policy responses and mobilisation of domestic and foreign capital for long-term investment.