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.

Section 73(9) adjudication must comply with principles of natural justice by providing a reasonable and effective opportunity to answer a proposed demand. Fixing the deadline for a reply and the personal-hearing date on the same day denies that opportunity, preventing the affected person from properly presenting its case. Such a procedural defect vitiates the adjudication order and requires fresh adjudication after an adequate opportunity of hearing.

Rule 96(10) of the Central Goods and Services Tax Rules, 2017, which restricted integrated tax refunds on zero-rated supplies, was previously struck down by a coordinate bench. Its subsequent omission reinforces that the restriction cannot be used to deny an integrated tax refund. The refund claimant is entitled to the refund together with applicable interest.

Anticipatory bail requires a reasonably founded apprehension of arrest. An arrest-authorisation order under section 69 of the Central Goods and Services Tax Act, 2017, communicated to the person concerned, is the foundational jurisdictional requirement for seeking that protection. Summons under section 70 requiring appearance or production of documents, without an existing arrest-authorisation order or imminent coercive action, do not establish a sufficient apprehension of arrest. In the absence of such an order, the apprehension remains speculative and anticipatory bail is not warranted.

Interest on borrowings used for real-estate project work-in-progress is deductible where the developer follows the percentage-completion method: project work-in-progress is stock-in-trade, not an asset acquired for business extension and first put to use, so the proviso to Section 36(1)(iii) does not require capitalisation. For a temporary advance to a group concern, disallowance is limited to interest actually charged to profit and loss, particularly where interest-free funds substantially financed the advance. Any non-allowable interest must be removed from project work-in-progress to prevent a later deduction as project cost when revenue is recognised.

Form C in Schedule IV of the Information Technology (Certifying Authorities) Rules, 2000 is amended to include fields for official address, organisation, and organisational unit. These entries are placed after residential address and before the mobile phone number field. The amendment takes effect upon publication in the Official Gazette and expands the prescribed information fields within the certifying-authority framework.