The 25% corporate tax rate for Assessment Year 2018-19 applied where a company's total turnover in the previous year 2015-16 remained below Rs. 50 crore. Total revenue of Rs. 48.72 crore, comprising Rs. 46.79 crore from operations and Rs. 1.93 crore as other income, remained within that threshold. The company was consequently subject to tax at 25% rather than 30%.

Revisionary jurisdiction under Section 263 requires a demonstrated error in the assessment order that is prejudicial to Revenue interests. Where the taxpayer has furnished complete particulars of legal and professional expenses, including their nature and purpose, and the assessment follows adequate enquiry, a revisional authority must identify a specific defect and explain the resulting prejudice. The power cannot be invoked merely to seek further verification or to conduct a fishing and roving enquiry. On these stated facts, revision of the assessment concerning the expense allowability was unjustified.

Interest awarded under section 28 of the Land Acquisition Act forms part of enhanced compensation and, unlike section 34 interest for delayed payment, does not become income from other sources. Amendments governing taxation of compensation interest do not alter that character. Revisionary jurisdiction under section 263 is unavailable where the Assessing Officer specifically examined the issue and adopted a legally possible view on a debatable question. An audit objection alone cannot render the assessment erroneous and prejudicial to the Revenue, while an unreasoned dismissal of a special leave petition is not binding law.

Section 153C treats the date on which seized material is handed over to the jurisdictional Assessing Officer and satisfaction is recorded as the deemed search date for applying the six-year assessment block under Section 153A. Where handover occurred during financial year 2021-22, only assessment years 2016-17 through 2021-22 fell within the assessable block. Assessment year 2015-16 therefore lay outside the prescribed period, rendering proceedings for that year time-barred and beyond jurisdiction.

Additions for unexplained cash credits in a concluded, unabated search assessment require incriminating material actually found during the search. An investigation report alleging accommodation entries, or a statement recorded during search that is unsupported by seized material, does not meet that requirement. Expiry of the period for issuing a scrutiny notice means the assessment remains concluded; non-filing of the original return does not make it pending. Nor does a return filed in response to a search-assessment notice itself become incriminating material. Consequently, an unexplained cash-credit addition resting only on those sources is unsustainable and liable to deletion.

Recorded petrol and diesel sale proceeds, supported by unrejected books, stock availability and sales records, do not become unexplained cash credits merely because specified bank notes were accepted during demonetisation; taxing them separately would duplicate taxation of the reported profit. Customer advances supported by booking orders, invoices, affidavits, identity documents and ledgers cannot be treated as unexplained credits merely because partial receipts were not completed sales. Corroborative additional evidence relevant to those advances should not be refused where refusal would breach natural justice. Application of Section 68 requires the recorded receipts or supporting evidence to be discredited.

Section 148 permitted reassessment for the relevant assessment year within six years from its end where escaped income exceeded the prescribed threshold. A document seized from a person's custody attracts a statutory presumption of ownership and truth of its contents; the person must rebut that presumption with credible supporting material. Assertions that the seized document or transaction belonged to a family member require confirmation, disclosed returns, books of account, or other substantiating evidence. An assessment is not invalid merely on a Document Identification Number objection where departmental records comply with the applicable requirement.

Section 145(3) permits rejection of books of account where their correctness or completeness cannot be verified. Non-production of books, bills and vouchers, failure to comply with creditor-verification notices, and lack of documentary support for a substantial fall in the net-profit rate justified rejection. In the absence of material displacing these findings, the rejection of accounts and consequential net-profit addition were sustained.

Tax deduction at source obligations on interest, earthwork and transport payments do not arise where truck income was declared under presumptive taxation and, after excluding transportation receipts, no remaining turnover triggered tax-audit requirements. Consequently, expenditure disallowance for failure to deduct tax is unsustainable. Interest on property-backed borrowings used for business is not disallowable merely on an allegation of non-business diversion without concrete supporting material. Where own capital exceeds loans and advances, advances may be presumed to have been made from own funds, preventing interest disallowance.

Sale consideration received on a transfer of shares is not assessable as unexplained cash credit where its nature and source are satisfactorily established. Banking records supporting the share purchase, coupled with transaction documents for the sale, purchaser confirmation, and an affidavit furnished during verification, link the receipt to an identified and evidenced share transaction. The receipt is therefore fully explained and no addition for unexplained cash credit arises.

Section 153C provides the applicable non-obstante assessment procedure where incriminating material relating to an assessee is seized during a third-party search. It overrides regular assessment and reassessment routes, including sections 143(3), 147 and 148, where proceedings are founded on that material. An assessment initiated under section 143(3) on the basis of such third-party search material is therefore invalid and liable to be quashed.

Cash-deposit additions were not maintainable where AIR and CIB data duplicated transactions in the same bank account and audited records reconciled deposits with recorded petrol-pump sales and business receipts. A capital-account difference did not constitute unexplained cash credit where capital introductions, tax refunds and withdrawals reconciled the apparent mismatch. Gross commission could not be taxed without deducting substantiated business expenses, leaving only disclosed net commission income taxable. FD interest pledged for a bank guarantee and miscellaneous receipts already credited to the profit and loss account could not be separately assessed as income from other sources, as that would duplicate taxation.

Section 80IA(4C) covered undertakings commencing electronic data interchange services within the prescribed period. Eligibility did not require end-to-end telecommunications services or complete independence from existing infrastructure. A separate undertaking could be established through dedicated equipment and infrastructure, technical personnel, regular service provision, and separately identifiable profits; use of existing networks and cables did not defeat that status. Services commercially launched as electronic data-transfer services remained eligible electronic data interchange services despite later being described as internet services, applying substance over form. The undertaking's profits qualified for the deduction.

Section 11 exemption requires valid registration under section 12A or 12AB for the relevant assessment year; provisional registration effective only from a later year does not satisfy that condition. Where charitable exemption is unavailable, taxable income cannot be assessed on gross receipts alone. Income must be computed on ordinary commercial accounting principles after verification of expenditure incurred wholly and exclusively for earning the receipts. Legitimate verified expenditure must be allowed, and tax liability confined to the resulting net income, if any.

Section 271AAB search-penalty liability depends on income qualifying as undisclosed income and on clear communication of the precise statutory charge. A residual cash addition based on judicial estimation and attributed to agricultural income or household savings, without seized material or an admission establishing undisclosed income, does not meet the statutory condition for search penalty. Show-cause notices and penalty orders must identify the applicable clause or limb of section 271AAB; omission of the charge prevents the assessee from responding effectively and infringes principles of natural justice.

Penalty proceedings under section 271AAB require the notice to state the precise charge and applicable statutory limb. Failure to specify the limb deprives the assessee of a meaningful opportunity to answer the particular allegation and constitutes a fatal defect in initiating the penalty. Applying coordinate-bench reasoning, the section 271AAB penalty was unsustainable and deleted.

Interference with dismissal of a miscellaneous application for non-appearance was not warranted prima facie because the assessee did not provide a proper explanation for its absence. The appellant could seek restoration of the application before the Tribunal within the stipulated period. The substantial questions of law remained unadjudicated and were left open.

Reassessment proceedings for Assessment Year 2021-22, initiated on allegations that excessive insurance commission had been routed through facilitators, were stayed pending the next hearing. The available material did not prima facie identify the petitioner as a facilitator or disclose information indicating that its income had escaped assessment. The interim relief prevented further reassessment action pending consideration of the notice's factual basis.

Section 16(5), retrospectively effective from 1 July 2017, permits input tax credit on invoices or debit notes for financial years 2017-18 through 2020-21 where the relevant return was filed by 30 November 2021. The provision operates notwithstanding the general time restriction under Section 16(4). Input tax credit disputes falling within this period require examination under the amended deadline, with taxpayers afforded a sufficient opportunity of hearing in accordance with principles of natural justice before further action.

GST registration cancelled for continuous non-filing of returns may be restored despite expiry of the statutory appeal limitation where outstanding statutory dues are paid. Although cancellation is permitted for continued return defaults and the appellate remedy had become time-barred, interference was granted because comparable circumstances supported restoration and the parties agreed. The cancellation was set aside, requiring revocation and restoration of registration upon payment of outstanding dues.