Reassessment notice under Section 148 for assessment year 2015-16, issued on 29 July 2022, fell outside the applicable limitation period. Under the governing Supreme Court position, notices for that assessment year issued on or after 1 April 2021 could not be completed within the period preserved by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The notice was consequently time-barred, requiring its quashing and the setting aside of consequential reassessment proceedings.

Deduction for eligible infrastructure projects under section 80-IA(4) remains available where tender terms, rights and obligations are materially identical to those previously accepted. Exempt-income disallowance under section 14A read with Rule 8D may be computed using the prescribed monthly-average investment method even where investments are acquired and redeemed within the year and are absent at both year-end balance-sheet dates. That disallowance increases book profit under section 115JB. CSR-related donations qualify under section 80G only after verifying the donee fund and all statutory conditions; donations to Swachh Bharat Kosh and Clean Ganga Fund are excluded.

Section 14A applies only to expenditure relating to income excluded from total income; it does not cover interest taxable at a concessional rate or interest arising between an Indian permanent establishment and its head office or overseas branches, which is treated as a transaction with self. Revaluation losses on outstanding forward contracts are deductible under mercantile accounting where an existing, reasonably estimable liability has crystallised. Interest-free funds exceeding exempt-income investments support a presumption that those investments used such funds. Broken-period interest on banking securities and workforce-rationalisation payments are revenue deductions in the stated circumstances. Head-office and global-system expenditure requires factual classification under section 44C before considering withholding or royalty consequences.

Income-tax treatment of banking and branch transactions permits revenue deduction for broken-period interest on securities held as stock-in-trade, excludes section 14A interest disallowance where interest-free funds financed exempt-income investments, and limits section 44C to specified head-office expenditure. Bad-debt write-offs are adjusted against the opening provision balance, while unrealised valuation gains on unmatured forward contracts are not taxable absent accrual; Indian-branch interest paid to head office or overseas branches did not attract withholding-based disallowance for the relevant year. Transfer-pricing rules apply to Indian permanent-establishment dealings with head office and overseas branches, and an Additional Commissioner may issue a section 92CA order absent proof of missing authorisation. Function-based benchmarking permits aggregation and set-off of linked money-market placements but rejects unsupported adjustments for advisory, support, correspondent banking, derivative-referral and incidental supervisory functions. Section 92CA does not determine income-recognition timing.

Income tax or TDS cannot be deducted from compensation payable for compulsory acquisition of land. This extends to the component forming part of enhanced compensation under Section 28 of the Land Acquisition Act, 1894. No lawful basis exists for withholding any portion of such compensation on account of income tax or TDS, requiring the compensation to be paid to landowners without those deductions.

Prepaid SIM-card and recharge-coupon distribution on a principal-to-principal basis does not create an agency relationship merely because the supplier imposes ownership, customer-documentation, or regulatory-compliance obligations. Distributors purchase products at a discount, independently set resale prices, and earn their margin on resale. Where that margin arises from the distributor's resale price and is neither paid nor credited by the supplier, it is not commission or brokerage requiring tax deduction at source under Section 194H. The tax-withholding mechanism therefore does not apply to the distributor's resale margin.

Section 68 requires an assessee claiming unsecured loans to establish the creditor's identity, financial capacity and the genuineness of the transaction through cogent evidence. Confirmations and payment by cheque alone do not establish creditworthiness where creditors deny advancing the loans or cannot satisfactorily explain their funding sources and preceding cash deposits. Failure to discharge this initial burden supports an addition for unexplained cash credits, and a concurrent factual finding that creditors lacked creditworthiness is not perverse on those circumstances.

Faceless assessment of capital gains cannot treat gross sale proceeds as taxable gains while disregarding documentary material supporting the cost of acquisition, transfer expenses, and reinvestment claims. Sale deeds, acquisition records, legal-expense evidence, and reinvestment documents furnished through the assessment portal require specific consideration. Denial of deductions and reinvestment benefits without identifying deficiencies, conducting enquiry or verification, or giving reasoned consideration is legally infirm. A fresh reasoned assessment, with a personal hearing, is required where the material submitted has not been addressed.

Clause (iv)(b) of Explanation 1 to section 153 treats receipt of a copy of an order setting aside a special-audit direction as the limitation trigger; unlike clause (ii), it does not require a certified copy. A digitally signed order communicated by email or fax was sufficient to start that period. Receipt by departmental authorities by 10 January 2026 meant limitation expired by 13 March 2026. The later special-audit direction, audit report and assessment were without jurisdiction, and returned income stood deemed accepted.

Chit foreman payments made to cure subscriber defaults are treated as debts arising in the ordinary course of the chit business; once written off, separate proof of irrecoverability is unnecessary, and they may alternatively qualify as business loss. Consistent treatment across unchanged assessment years supports deductibility of interest on security deposits, commissions and gifts paid to associated entities. Recurring turnover-based payments for a terminable, non-exclusive and non-transferable logo licence remain revenue expenditure because no intellectual-property asset or enduring benefit is acquired. OD interest remains allowable where surplus own funds exceed interest-free advances.

Tax-refund adjustment constitutes coercive recovery and cannot be used against demands protected by a subsisting unconditional stay. Refunds adjusted against demands for Assessment Years 2016-17 to 2018-19, which were treated as non-collectible, must be reversed with statutory interest. While a stay application remains pending, recovery through refund adjustment is barred; for the Assessment Year 2021-22 demand, retention is limited to 20% under recovery guidelines, with excess adjustment refunded and the balance demand stayed pending appeal.

Standing to challenge a search and seizure authorisation directed at a company belongs to the affected company. An additional director does not obtain a personal cause of action merely by holding that office and therefore cannot invoke writ jurisdiction to contest the authorisation. Any grievance concerning the legality of the search or its authorisation must be pursued by the company.

Sufficient cause for condoning a prolonged delay in re-presenting tax appeals requires a reasonable, plausible and bona fide explanation covering the entire period of delay. General reliance on administrative workload, simultaneous appeals, voluminous records and procedural requirements does not explain sustained inaction. Government departments remain subject to limitation rules and cannot obtain condonation merely because of bureaucratic processes. Consistent treatment is required where delayed appeals arising from the same appellate order have previously not been entertained. Condonation of the Revenue's delay was declined in favour of the assessee.

Wrongful PAN linkage to bank accounts and cash transactions belonging to a company removed the factual basis for attributing the related income to an individual taxpayer. Assessment under best-judgment and faceless-assessment provisions, consequential penalty proceedings, tax demands, and revision could not stand without that attribution. The taxpayer bore no tax or penalty liability for the company's transactions; the assessment, penalties, demands, and revisional action were set aside.

Reassessment of a disclosed long-term capital loss from the sale of immovable property cannot rest solely on reconsideration of material examined during the original scrutiny assessment. Where sale consideration, capital-gain computation, purchase deeds, co-owners' shares and land records were produced and accepted, reopening requires fresh tangible material indicating escaped income. Reopening on the same transactions without such material constitutes a change of opinion and invalidates the reassessment notice and order.

Reassessment under Sections 148 and 148A requires a valid basis to conclude that income has escaped assessment. Disclosure of cryptocurrency sales, purchases, opening and closing stock, and resulting income in the return, reply and reconciliation statement precludes a finding of non-disclosure merely because the return form lacks a separate cryptocurrency reporting head. Because the premise of undisclosed Bitcoin transactions was factually incorrect, the Section 148 notice and Section 148A(d) order were quashed.

Reassessment requires material indicating that income chargeable to tax escaped assessment in the specific assessment year proposed for reopening. Unsecured loans had been obtained and disclosed in the preceding year, while the relevant year's ledger reflected only interest expenditure. The loan amounts cited in the reopening material also did not match the recorded interest amount. Because the alleged loan transactions did not pertain to the year reopened, the reassessment lacked a sustainable factual basis and was unsustainable.

Refund of payments made by a partnership firm towards an individual partner's outstanding income-tax demand is unavailable where fixed deposits and a cheque were voluntarily tendered. A bank attachment, without more, does not establish coercive recovery. Where the revenue authorities were not informed of an alleged change from proprietorship to partnership when payment was made, departmental action is not rendered illegal, erroneous, or arbitrary. Any claim arising from the firm's payment of a partner's tax liability remains an inter se dispute between the partners rather than a basis for refund from the tax department.

Section 107 of the CGST Act confines an appellate authority's power to condone delay to the prescribed outer limit; equitable considerations or constitutional relief in another proceeding cannot enlarge that statutory jurisdiction. Restoration of cancelled registrations pursuant to appellate orders may render a departmental challenge infructuous where undoing the restoration would disturb intervening business and compliance actions, leaving no effective relief. The statutory appeal against cancellation remains independent of revocation under Rule 23: expiry of the portal-based revocation period does not extinguish the right to pursue an appeal.

Section 107 confines an appellate authority's power to condone delay to the statutory outer limit; equitable considerations and constitutional relief under Article 226 cannot enlarge that jurisdiction. Where registration cancellation orders have been implemented through restoration of registration and taxpayers have resumed business and compliance, a departmental challenge may become academic because annulment would disrupt intervening transactions. The appeal remedy under Section 107 operates independently of the revocation procedure under Rule 23, so inability to file a revocation application after the prescribed period does not extinguish the right to challenge cancellation in appeal. Restored registrations and their consequential legal effects remain undisturbed.