Additional contractual compensation requires proof that work fell outside the agreed scope and that the parties agreed to pay separately for it. A comprehensive scope covering architectural, structural and building-services coordination, together with an augmentation purchase order that identified no distinct extra work, did not establish such entitlement. Unpaid milestone payments require proof of completion of the contractual deliverables triggering each payment stage. The consultant did not produce CAD files, finished or GFC drawings, or evidence of dispatch of complete multidisciplinary drawings; an unsupported list of drawings was insufficient. The recovery claim therefore lacked proof of both contractual entitlement and performance conditions.

Penalty for under-reporting or misreporting income does not apply where an assessee gives a bona fide explanation and fully discloses all material facts substantiating it. A gratuity provision disallowable under Section 40A(7) had been expressly disclosed in Form 3CD, but was inadvertently not added back in the return. This disclosure established that no material facts were concealed or withheld. The omitted disallowance therefore fell within the Section 270A(6)(a) exception, and no penalty under Section 270A was leviable.

Opting for the Direct Tax Vivad Se Vishwas Scheme, 2024, after filing the required application removes the need to keep a pending tax appeal alive. The appeal may be dismissed where the taxpayer intends to avail Scheme benefits, while preserving liberty to seek recall if the Revenue does not accept the taxpayer's declaration. This approach enables resolution under the Scheme without permanently prejudicing the taxpayer's position if the declaration fails acceptance.

Prior approval for search assessments must be validly granted. A common approval covering multiple assessment years was treated as incapable of satisfying the approval requirement. Characterising approval as administrative, without examining its contents, did not cure the defect. The resulting search assessment was invalid and quashed for lack of valid approval under the Income-tax Act.

Foreign tax credit remains available despite delayed furnishing of the prescribed supporting form where the governing rule fixes a filing time but does not expressly deny credit for non-compliance. The filing requirement is procedural and directory, and cannot extinguish substantive entitlement to credit for foreign taxes paid or treaty-based relief. The claim must therefore be assessed on its merits after verification of supporting evidence. Delay in filing an appeal may be condoned where sufficient cause is established, no mala fide intent is shown, and refusal would prevent consideration on merits.

Rejection of audited books of account requires a prima facie basis for disbelieving declared financial results; without that basis, estimated profit cannot be sustained and the audited loss is accepted. Outstanding liabilities may be treated as unexplained cash credits where the taxpayer fails to produce supporting records or otherwise discharge the evidentiary burden. Audit disclosures of accounting irregularities, missing documentation and unreconciled liabilities support taxation of unsupported liabilities.

Commission income from alleged accommodation entries was estimated at 0.15% of the entry amounts. Consistent estimates at that rate in the taxpayer's immediately succeeding assessment years were applied under the principle of judicial discipline, rather than the proposed 1% rate. The income was therefore assessed using the 0.15% commission rate.

Reopening of assessment under section 147 based on client code modification information requires recorded reasons identifying the assessee's transactions and showing independent evaluation. Mere reproduction of investigation-wing information and an assertion of escaped income are cryptic and vague, indicating non-application of mind. On that basis, the section 147 reopening and consequential assessment under section 143(3) were quashed.

Reassessment after a completed scrutiny assessment requires fresh tangible material and the Assessing Officer's independently formed belief that income escaped assessment. Reopening based solely on an audit objection regarding tax deduction on rent payments, where the original scrutiny had considered the financial statements, tax audit report and relevant expense claim, amounts to an impermissible review of an issue already examined. In the absence of new material or independent satisfaction, the reassessment is invalid and the consequential assessment is liable to be quashed.

Additional income arising from shortages of finished goods and raw materials detected during survey requires corroborative material; a survey admission alone is not conclusive. In footwear manufacturing, stock valuation is inherently approximate because of varied raw materials, work-in-progress, wastage and excess consumption. These factors support estimating income from shortages using a reduced gross-profit rate. The applicable gross-profit rate for the retained shortages is 10% rather than 20.91%.

Commission paid to non-resident export agents is not disallowable for failure to withhold tax where the agents have no permanent establishment in India and render no services in India. In those circumstances, the commission is not taxable in India and no withholding obligation arises. Sample design and development charges paid to foreign parties are likewise not disallowable where the amendment to the taxability provision relied upon was not in force when payment was made. A later amendment cannot impose a withholding obligation for an earlier period when compliance was impossible at the time of payment.

Profit estimation where books are not produced should account for the declared net-profit rate and comparable statutory presumptive benchmarks. A 12% rate was considered excessive where the declared rate exceeded preceding years; taxable income was recomputed at 6.5% of declared turnover. Contractual receipts that include closing work-in-progress cannot replace declared turnover for income estimation merely because the contractor deducted tax at source on those receipts. Income should therefore be computed by applying the revised profit rate to declared turnover rather than to receipts inclusive of work-in-progress.

Construction expenditure for Section 54 includes costs that make a residential unit livable and form an integral part of its construction. Expenditure on lift installation, CCTV and air-conditioning services met this test and qualified for the Section 54 claim. Consequently, excluding an estimated portion of those expenses was unsustainable, and the disallowance of the construction expenses was deleted.

Form No. 3CL certification by the prescribed authority determines eligible research and development expenditure for weighted deduction under Section 35(2AB). Once the authority has inspected the facilities and approved expenditure, the Assessing Officer cannot reassess the technical character of the research, employee qualifications, or qualifying capital expenditure. Later survey findings do not displace certification issued for the relevant assessment years. The weighted deduction remains allowable to the extent of expenditure certified in Form No. 3CL.

LFC reimbursements involving foreign travel did not qualify for exemption under section 10(5) read with rule 2B. However, an interim judicial direction treated LTC reimbursements as not constituting income for tax-deduction purposes and placed the eventual tax liability on employees. Compliance with that direction did not create an employer default under section 201(1), even if the substantive exemption was later found unavailable. Consequently, no interest under section 201(1A) or related demand arose for the earlier reimbursement periods covered by the interim direction.

Settlement applications before the Interim Board concern the availability of relaxation under section 119(2)(b) where an assessment case remained pending on the application date. A coordinate Bench decision governs the issue in connected settlement matters. The pending assessment requirement on the application date and the scope of statutory relaxation form the central legal points.

Reassessment cannot be initiated merely because the assessing authority later takes a different view of a capital-gain claim already examined in an original scrutiny assessment. Specific enquiries and disclosures concerning the sale of shares, capital-gain computation, and deduction claim established that the material relied on for reopening had been considered earlier. Sections 147 and 148 permit reassessment on legally sustainable grounds but do not confer a power to review a concluded assessment on the same material. Reopening founded solely on a change of opinion is therefore impermissible, rendering the order under section 148A(d) and the reassessment notice liable to be quashed.

Income tax or tax deduction at source cannot reduce compensation payable for compulsory land acquisition where no material justifies withholding. Earlier land-acquisition rulings establish that enhanced compensation remains payable without such deductions. Amounts withheld from enhanced compensation on this basis must be released, with release directed within three months. The principle prevents tax withholding from diminishing the compensation due to persons whose land has been compulsorily acquired.

Anticipatory bail in serious economic-offence investigations is exceptional and depends on the gravity of allegations, each accused's individual role, public interest, and the need for effective custodial interrogation. The alleged primary decision-maker, attributed overall control of the companies, acceptance of clandestine clearances, and responsibility for GST liability, was considered unsuitable for pre-arrest protection while the investigation continued. An ancillary field-level participant acting under that person's directions was treated differently because of the limited role and qualified for protection. Pre-arrest protection therefore turns on individual culpability and investigative necessity rather than identical treatment of all accused.

Tariff-rate-quota sugar exports from India to the European Union are allocated up to 5,841 MT for October 2026-September 2027, while the allocation also identifies an earlier quota period. Exports remain free subject to applicable restrictions. Where required for preferential treatment, Certificates of Origin depend on recommendations concerning the eligible entity and quantity. APEDA operates the quota, while other European Union-specific certification and prescribed reporting requirements continue to apply.