Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.

Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.

Revisionary jurisdiction under section 263 may be invoked where the assessment record gives a prima facie basis to regard an assessment as both erroneous and prejudicial to Revenue; final determination follows inquiry and hearing. A co-operative society deduction requires examination of the timely-return condition under section 80AC. Queries into cash deposits do not satisfy that obligation where they do not address the separate statutory eligibility condition, and a return furnished only after a reopening notice does not meet the prescribed filing requirement. Reassessment may examine the deduction when claimed co-operative income is offered to explain the cash deposits that prompted reopening. The revision was sustained and the appeal dismissed.

Cloud-based communication platform subscription fees are not royalty where subscribers receive only limited, non-exclusive access and no copyright, source code, intellectual property, or embedded process is transferred. The provider's use of technology and processes to deliver the service does not give subscribers a right to use those processes. Such receipts constitute business income and are not taxable in India absent a permanent establishment. Tax deducted at source credit requires factual verification before it may be allowed in accordance with law.

Penalty for under-reported income is excluded where the taxpayer provides a bona fide explanation and fully discloses supporting material facts. Uploading audit records, paying relevant taxes before reassessment, and filing income accepted without additions supported cancellation under section 270A. Delayed tax-audit reporting does not attract penalty where reasonable cause is established: director disputes during the pandemic delayed account finalisation, while prompt upload after finalisation and absence of prejudice supported cancellation under section 271B.

Regular scrutiny assessment under section 143(3) requires the Assessing Officer to exercise quasi-judicial discretion independently. Absent statutory authority, consultation with and prior approval from an Additional Commissioner during the assessment process constitutes unauthorised superior-officer participation and negates the Assessing Officer's independent application of mind. Such assessments are void ab initio and liable to be quashed. A superior officer may consult subordinates without displacing the superior officer's discretion, but subordinate consultation with a superior officer displaces the discretion vested exclusively in the Assessing Officer.

Section 115BAA concessional corporate tax option requires cumulative compliance with prescribed conditions; claiming additional depreciation, which the regime prohibits, while calculating tax under the normal regime invalidates the option despite filing Form 10-IC. However, disallowance of additional depreciation through section 143(1) return processing is not permissible where it turns on a disputed legal position, particularly where the taxpayer's clarification was not considered. The invalid option therefore did not sustain the adjustment, which was deleted.

Section 43A applies only where capital assets are acquired from outside India; foreign-currency denomination or an overseas ECB source does not satisfy that condition for assets acquired in India. Unrealised foreign-exchange gains or losses on year-end reinstatement of ECB liabilities used for indigenous capital assets therefore fall outside section 43A. Section 43AA governs such foreign-exchange fluctuations and requires recognition in accordance with applicable statutory and accounting requirements, without treating the capital or revenue character of the underlying transaction as determinative. The resulting exchange gain must be given effect in computing taxable income.

Reassessment of unreported immovable-property sales may be initiated where transfer information, non-filing of a return, and unsupported exemption claims establish a live link to escaped income; a prima facie belief, rather than conclusive proof, is sufficient at reopening. Sanction is valid where the approving authority considers detailed recorded reasons, demonstrating application of mind. Agricultural land must be classified by measuring statutory distance from the outer limits of the municipal corporation prevailing on the transfer date, not superseded municipal limits. A dishonoured sale-consideration cheque does not sustain a non-receipt claim where the sale deed remains uncancelled and parties have compromised. Indexed-cost and residential-investment exemption claims require supporting evidence and verification.

Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.

Unaccounted cash receipts from flat sales are taxable only to the extent of the profit embedded in the receipts; gross sale proceeds do not themselves constitute income. Where corresponding sales are accepted, alleged non-genuine steel purchases sourced through the grey market likewise permit taxation only of the embedded profit element, not the full purchase value. Search-seized electronic records meeting statutory admission requirements, when corroborated by statements recorded during search, remain reliable evidence despite a belated retraction unsupported by cogent material. A stamp-value addition was restored because it was not contested, without examination of its merits.

Documentary substantiation governed the disputed tax claims and electronic-record addition. Children's tuition-fee deduction was confined to payments supported by receipts, while the unsupported balance was disallowed because the claimant did not discharge the burden of proof. House rent allowance exemption was also disallowed for lack of supporting evidence. The challenge alleging inadequate hearing failed because four appellate notices were not complied with. Seized Excel entries identifying amounts as loans received from the assessee supported the unexplained-investment addition, as no material established that the entries were wrongly classified or represented company business transactions.

Damaged guar gum inventory valued under Accounting Standard-2 at cost or net realisable value, whichever is lower, may be written down where damage prevents recovery at normal sale value; revaluation cannot displace that disclosed method. Non-moving or deteriorated inventory may similarly be written off when corrosion or wear and tear reduces its value. Cash deposits during demonetisation, already recorded as sales in audited books and supported by sale bills, delivery challans, and sales and stock registers, are not unexplained money without contrary material. The additions for stock revaluation and cash deposits were deleted, and the Revenue's appeal was dismissed.

Reverse burden for notified gold under section 123 arises only where tangible material supports a reasonable belief of smuggling; inland seizure or absence of foreign markings alone is insufficient. Assessment requires cumulative consideration of carriage, the article's nature, statements, documentary provenance and accounting trail. Registered suppliers and tax invoices supporting domestically acquired gold may establish lawful provenance unless shown to be false or unconnected with business stock. The claimant may discharge the burden on a preponderance of probability through reliable documents and circumstances, without proving uninterrupted physical identity of fungible gold unless circumstances warrant it.

HSN Explanatory Notes guide customs tariff classification where the Tariff Schedule gives no contrary indication. A Protector Tube shown by supplier material to be 100% PVC falls under the plastic-tube tariff entry rather than the rubber-hose entry; a certificate of origin using the latter classification prevents preferential customs benefit. Brake hose brackets and connectors designed solely or principally for automobile brake systems classify as motor-vehicle parts rather than generic plastic or residuary entries, resulting in differential duty. Under self-assessment, intentional incorrect tariff declarations causing short payment can support extended limitation and customs penalties, particularly where prior classifications, later duty-beneficial changes, admissions, and voluntary payments evidence misdeclaration.

End-use based customs duty concession for imported lithium-ion cells applies only where the specified manufacture results in a new product with a distinct nature, character, use or name. Cells damaged, rejected or scrapped during battery or battery-pack assembly or testing, and subsequently sold as scrap, do not satisfy that end-use. In the absence of a separate allowance for process loss or wastage, they are treated as unutilised or defective goods under the IGCR Rules. The concession must therefore be reversed through payment of the differential duty otherwise payable at import, with applicable interest. Duty is calculated on the quantity and value assessed at import, without regard to the scrap sale value.

Woven man-made fibre label tapes, imported in rolls but specially processed for durable printing and intended solely to display garment-related information, fall within the heading for woven labels and similar textile articles rather than narrow woven fabrics. Their subsequent printing or cutting does not prevent them from possessing the essential character of labels. Where the material composition is confirmed as man-made fibre, classification applies under the specific tariff item for woven labels of man-made fibre rather than the residual entry. Products so classified fall within the concessional IGST entry for textile labels, subject to verification of declared characteristics and applicable conditions.

Bulk drugs and active pharmaceutical ingredients qualify as drugs and medicines where they meet the applicable pharmaceutical definitions, even when imported for examination, testing, clinical research, bioavailability or bioequivalence studies. The description-based IGST rate entry covering drugs and medicines under any chapter applies to qualifying APIs, provided they do not fall within the specified nil-rate exclusion. The entry is not restricted to finished formulations under Chapter 30. Where APIs are chemically classifiable under Chapters 28 or 29, the specific drug entry prevails over the general inorganic or organic chemical entries. Qualifying goods are therefore chargeable at 5 per cent IGST.

Bulk drugs and active pharmaceutical ingredients qualify as "All Drugs and medicines" for concessional IGST treatment where they meet the drug description and are not within the prescribed nil-rate exclusion. The statutory drug definition includes substances intended for use as drug components; importing APIs for testing, clinical research, clinical trials, bioavailability, or bioequivalence studies does not alone change that status. The drugs-and-medicines entry applies across tariff chapters and prevails over general Chapter 28 or 29 chemical entries under the specific-over-general classification principle. Qualifying APIs attract IGST at 5%, subject to examination of the exclusion for each imported product.

Final debt recovery adjudication fixing personal guarantors' joint and several liability for the entire dues prevents them from re-agitating a claim that their guarantees were limited to the market value of mortgaged properties in collateral proceedings under Section 114 of the Code. Guarantee clauses requiring payment on default and permitting enforcement despite unrealisable security operate with mortgage-related provisions, rather than creating a liability cap. A repayment plan requires the prescribed affirmative creditor vote; the Adjudicating Authority cannot substitute its commercial view where that approval is absent. No prejudice or vitiation of the statutory process was established.