Section 14A read with Rule 8D does not permit disallowance of expenditure where no exempt income was earned, received, or receivable during the relevant previous year. For assessment year 2017-18, the absence of exempt income precluded any disallowance under these provisions, consistent with the binding jurisdictional position.

Reassessment initiated more than three years after the relevant assessment year requires escaped income meeting the statutory threshold. Although the order under Section 148A(d) alleged escaped income above INR 50 lakh, the final reassessment addition, computed at 2% of alleged accommodation entries, was INR 24,21,552. As the final addition fell below the applicable threshold under Section 149(1)(b), the reassessment proceedings and reassessment order were invalid and quashed.

Section 147 reassessment cannot rest solely on material already examined during a completed scrutiny assessment under Section 143(3). Where financial statements and furnished particulars were considered in the original assessment, reopening based only on the existing assessment record constitutes a change of opinion rather than a valid reason to believe that income escaped assessment. Fresh tangible material obtained after completion of the original assessment is required to support such reassessment; absent it, the reassessment proceedings are invalid and liable to be quashed.

Section 69A additions for jewellery require evidence beyond an ad hoc estimate. Customary ownership, including married daughters' streedhan retained at the parental home, may be established through affidavits, marriage photographs and applicable CBDT jewellery-holding guidance. Without departmental inspection, valuation, or cogent material connecting jewellery to undisclosed income, an addition is unsustainable. Likewise, documented bank withdrawals exceeding cash found can establish its source, preventing an unexplained-cash addition. Credible evidence of ownership and source therefore defeats unexplained-assets additions lacking contrary material.

Section 43B(d) requires actual payment for deduction of specified interest, but interest liability converted into cumulative redeemable preference shares under a corporate debt restructuring arrangement did not warrant disallowance. The applicable High Court precedent retained binding force because a pending special leave petition, without a Supreme Court stay, reversal, or modification, did not displace it. Consequently, the disallowance relating to the converted interest liability was deleted.

Settlement immunity under the Income-tax Act cannot extend to a prosecution instituted before the settlement application, even where the tax liability is resolved. That statutory bar does not displace inherent criminal jurisdiction to assess whether continuation of prosecution is justified. Where a settlement order is final, liabilities have been paid, no breach or challenge exists, and proceedings have remained pending for many years, continuation may serve no meaningful penal purpose and amount to abuse of process. The criminal complaint, summoning and consequential proceedings were quashed.

Section 127 requires recorded reasons for a transfer of jurisdiction and, where feasible, an opportunity of hearing; the hearing requirement is relaxed for transfers within the same city, locality or place. Following search-related group centralisation, assessees who sought or knew of centralisation, filed returns and participated before the transferee officer without timely objection may be treated as having waived technical natural-justice objections. Challenges concerning assessment notices, opportunity, and additions should ordinarily use the statutory appeal mechanism rather than writ jurisdiction where that remedy is effective. Group centralisation consequently remains operative, with assessment challenges to be pursued through statutory appeals.

Taxability of non-compete consideration was governed by an existing binding determination on corresponding receipts. Because the consideration fell within that established treatment, uniformity required the same tax result. The addition relating to the non-compete fee was therefore unsustainable and was deleted, with the substantial questions resolved in favour of the assessee.

Transfer-pricing comparability under Rule 10B requires assessment of market conditions, assets employed and risks assumed. As the Rules prescribe no statutory upper or lower turnover threshold, an upper turnover filter of Rs. 200 crore can be applied as a rational factual benchmark for determining the arm's length price. Interference with that comparability determination requires a specific showing of perversity. Application of the Rs. 200 crore upper turnover filter was treated as valid in the assessee's transfer-pricing analysis.

FCRA appeals against refusal of registration are to be heard by a Division Bench because they are treated like appeals from original decrees and lack monetary valuation. Rule 9 requires Form FC-3A applicants to accurately disclose whether their character is religious, including the applicable religious classification. Zen Buddhist philosophy is religious; describing a religious organisation as non-religious while conducting religious programmes constitutes material misrepresentation and may justify refusal. Sections 11 and 12 do not absolutely bar religious organisations from registration, but registration is discretionary rather than vested. Educational or cultural instruction differs from worship and rituals, while conversion-related activities are statutorily prohibited. Discretion remains reviewable for illegality, perversity, non-application of mind, or disregard of relevant material.

Assessments founded solely on PAN-linked Form 26AS and risk-management data require disclosure of adverse material and independent verification when a taxpayer denies the reported transactions and alleges PAN misuse. Portal information, unsupported by inquiry from the alleged vendor or other cogent evidence, does not establish the taxpayer's connection with the transactions. Aggregating cash-payment and corresponding Form 26AS figures may duplicate alleged turnover. The Revenue bears the evidentiary burden to establish that connection. An appellate remedy may be ineffective where exceptional demands, required security or deposits, and accruing interest materially prevent access to relief. Fresh action must rest on cogent material and comply with applicable limitation requirements.

Material turnover discrepancies between VAT returns and income-tax accounts may support reassessment where VAT returns were not shown to have been disclosed during the original assessment. Reconciliation based on MRP reporting, duty, freight and local taxes requires factual verification in reassessment proceedings rather than writ review. A notice issued beyond four years may therefore rely on possible income escapement where full and true disclosure is not established. For notices issued before 1 April 2021, Section 148A does not apply; preliminary objections limited to jurisdiction do not require withdrawal where they concern reassessment merits.

Pre-amendment consideration for the sale of self-generated trademarks and trade brands is capital in nature but is not chargeable to capital gains where the cost of acquisition and improvement is unascertainable and no retrospective deeming rule applies. A dissolution clause providing indefinite, profit-linked payments may assign user rights rather than transfer ownership; subsequent consideration for ownership rights is therefore not royalty, annuity, or income from other sources. An arbitral award determining ownership and entitlement binds its parties unless evidence supports a colourable or non-genuine arrangement. Where the related tax addition does not survive, concealment penalty is not leviable.

Condonation of delay in electronically filing Form 10B under Section 119(2)(b) was granted despite substantial delay because the audit report had been physically signed within the prescribed period, the former accountant failed to upload it without the assessee's knowledge, and the lapse was promptly remedied after discovery. COVID-19 disruption and the death of the successor accountant supported the explanation. Payment of costs within the stipulated period sets aside the rejection and requires processing of the return as if Form 10B had been filed on time; non-payment results in dismissal of the writ petition.

Retrospective validation of reassessment jurisdiction is constitutionally sustainable only when legislation removes the statutory defect underlying earlier jurisdictional rulings; it cannot merely override those rulings while the governing faceless scheme remains unchanged. Section 151A and the 2022 Scheme require automated allocation and faceless reassessment, including the interlinked pre-notice process under section 148A and notice under section 148, leaving Jurisdictional Assessing Officers without authority to initiate proceedings outside that mechanism. Concurrent-jurisdiction notifications and non-compliant transfer to the National Faceless Assessment Centre do not cure that defect. An amendment expressly commencing after repeal cannot be inserted into the repealed Income-tax Act, 1961.

Deduction for provisions for bad and doubtful debts under the first proviso to section 36(1)(viia)(a) operates as a separate optional benefit from the main-clause deduction. The phrase "at its option" gives the assessee the choice to claim the special deduction for assets classified under RBI guidelines as doubtful or loss assets; it cannot be treated as redundant or made conditional on the Assessing Officer's discretion. Allowance of deduction under the main clause does not, by itself, exhaust or bar the first-proviso deduction, provided the RBI classification, prescribed conditions and statutory ceiling are satisfied.

Reassessment initiated solely on an alleged withholding-tax default and a consequential disallowance cannot continue where proceedings establish that the payee had no tax liability, no withholding obligation arose, and the taxpayer was not an assessee-in-default. The disallowance lacks an independent basis once the alleged failure to deduct tax is negated. Reassessment must rest on the grounds disclosed in the notice; an unspecified alternative ground cannot subsequently cure the failure of its stated basis. Consequently, reassessment founded only on the failed withholding-tax premise is unenforceable and must be closed.

Section 264 revisional jurisdiction may consider a new question or point of law only where it arises from facts already available in the assessment record. It cannot admit a fresh claim requiring facts outside that record, because doing so would effectively allow revision of the return after the statutory deadline. The Tribunal's appellate powers do not expand either the revisional authority's powers or the assessing authority's jurisdiction to entertain an otherwise time-barred claim. Consequently, a fresh claim not made through a timely revised return cannot be raised in revision.

Recipient-specific GST exemptions under Serial Nos. 3 and 3A apply only where specified pure or composite services are supplied directly to the Central Government, State Government, Union territory, local authority, Governmental Authority, or Government Entity in connection with prescribed functions. Manpower supplied by a subcontractor to a private principal contractor does not meet that recipient condition, even where the services support a Government water-supply project. Ultimate use in the Government project does not change the private contractor's status as the immediate recipient. The subcontract supply remains taxable, with GST stated to apply at 18%, subject to applicable classification and rate notification.

Section 107 prescribes a three-month appeal period and permits the First Appellate Authority to condone delay only for one further month on sufficient cause. That statutory outer limit cannot be enlarged through the appellate process, although constitutional writ jurisdiction may provide exceptional relief. Restoration of cancelled GST registrations pursuant to appellate directions may render a departmental challenge academic where businesses have resumed operations and subsequent transactions would be unsettled. The inability to apply for revocation through the common portal under Rule 23 does not extinguish the independent statutory right to appeal cancellation under Section 107.