House-property loss and Chapter VI-A deduction claims require reliable evidentiary substantiation. Partly self-serving and inconsistent material did not support allowing the claims in full. Income was estimated at 10 per cent of the aggregate disallowance, restricting the additions accordingly. The resulting addition was taxable at normal rates rather than under the special tax regime under Section 115BBE.

Section 158BD permits block assessment of a person other than the searched person only when search material reveals undisclosed income belonging to that person and jurisdictional satisfaction is recorded. Transactions already entered in the books of account and reflected in returns subject to regular assessment do not, without incriminating search material, establish undisclosed income for this purpose. Absence of a basis or satisfaction note for assuming jurisdiction further defeats the assessment. Block assessments unsupported by search material evidencing undisclosed income are therefore invalid.

Section 153A assessment additions require incriminating material discovered during a search. Statements recorded under Section 132(4) may carry evidentiary value but do not independently constitute incriminating material. Such statements can support an addition only where they have a nexus with corroborative incriminating evidence found during the search. A factual deletion of additions is not subject to reappreciation under Section 260A. Accordingly, an uncorroborated search statement alone cannot sustain additions in a Section 153A assessment.

Merits adjudication was required where the Tribunal had the factual material, grounds, and a detailed first-appellate order for one assessment year before it. Treating both years alike solely because the first-appellate order for the other year lacked reasons amounted to non-application of mind. The restoration of both matters without deciding the Revenue's appeals and the assessee's cross-objections was unsustainable. The Tribunal was required to determine the disputes on merits after hearing both sides.

For search assessments under Section 153A, pending assessments abate, but completed or unabated assessments may be reassessed only when incriminating material is unearthed during the search. Additions founded solely on regular books of account, land-sale information, or estimated profits cannot be sustained in an unabated assessment without such material. The separate reassessment power under Sections 147 and 148 remains available only where its statutory conditions are fulfilled. This distinction limits search-based reassessment of completed assessments while preserving reassessment under the independent statutory regime.

Reassessment founded solely on a transfer-pricing adjustment and material already examined during scrutiny is impermissible where the original assessment lapsed because no final assessment order followed the draft order within the statutory time. The reassessment mechanism cannot cure, bypass, or indirectly extend the limitation applicable to completion of the original assessment. Absence of fresh material prevents reopening based on the same transfer-pricing issue.

Interest income earned by a co-operative society from investments with a co-operative bank qualifies for deduction available for income derived from investments with other co-operative societies. The exclusion applicable to a co-operative bank's own deduction claim does not prevent another co-operative society from claiming deduction on such interest. The tax-deduction-at-source provision concerning interest payments does not remove co-operative banks from the class of co-operative societies for this purpose. Consequently, interest from investments with co-operative banks remains eligible for the deduction.

Approval of a corporate insolvency resolution plan extinguishes past claims, including statutory dues, for periods before approval. Its binding effect prevents reassessment proceedings against the corporate debtor for a pre-plan assessment year, even where fresh information later emerges regarding alleged transactions before plan approval. Consequently, pre-resolution-plan tax liabilities cannot be pursued through a newly initiated reassessment.

Draft assessment orders under Section 144C(1) must be made and forwarded within the applicable limitation period under Section 153, including any extension arising from a transfer-pricing reference. Expiry of that period renders a subsequently issued draft order time-barred and without jurisdiction. Final assessment orders, demand notices and penalty show-cause notices founded on such an invalid draft order cannot survive. Availability of a statutory appellate remedy does not bar writ jurisdiction where the assessment proceedings suffer from a clear jurisdictional defect caused by limitation expiry.

Section 148A(1) requires a reassessment show-cause notice to provide the information suggesting income escapement, including the relevant transaction, valuation or computation basis, and statutory basis, so that the taxpayer has an effective opportunity to respond. Supplying that foundational information after expiry of the limitation period under Section 149(2)(b) cannot retrospectively cure an invalid notice, and a consequential Section 148 notice cannot validate the defective initiation. Section 56(2)(x) does not apply merely because proportionately allotted fresh rights shares are subscribed below computed market value where the shareholder's percentage holding remains unchanged; such allotment does not establish receipt of property from another person for inadequate consideration.

Assessment transfer and centralisation under Section 127 may be justified where a search yields material linking an assessee to the searched group and related entities. Centralisation facilitates coordinated investigation and assessment of matters arising from the same search. A transfer order does not finally determine tax liability, and the assessee may contest the assessment on merits after relevant material is supplied. On those grounds, transfer to a Central Circle is treated as valid and non-arbitrary.

Review petitions challenging a criminal-appeal judgment on wilful tax-evasion prosecution were dismissed because the filing delay lacked satisfactory explanation and no ground for review existed on merits. The proceedings concerned prosecution immunity available through Settlement Commission procedures, the binding effect of CBDT circulars and prosecution guidelines, and statutory sanction and sanctioning-authority competence for prosecution.

Special leave petition concerning unexplained gold found in an appellant's locker involved four 24-carat gold bars rather than gold jewellery. The Supreme Court found no ground to interfere with the impugned judgment under Article 136 of the Constitution and dismissed the petition. The legal point centres on the characterisation of the seized gold as bullion bars, not jewellery, and the Court's discretionary refusal to grant special leave.

Recovery of tax dues through application of seized assets raises the interaction between recovery powers under section 226(4) and the application of seized assets under section 132B. Where seized amounts are also under investigation and provisional attachment under PMLA, the central issue is whether PMLA's overriding provisions and the characterisation of assets as proceeds of crime take priority over tax recovery. Competing non-obstante clauses require determination of which special statutory regime governs the assets.

Validity of reassessment notices after statutory amendment and TOLA raises the requirements for sanction by the specified authority, pre-notice procedure under section 148A, and information suggesting that income has escaped assessment. The issues also include whether reopening based solely on a change of opinion is impermissible and whether the statutory information threshold for issuing a notice under section 148 is satisfied. These requirements govern the legal validity of reassessment proceedings.

Special leave petitions concerning penalties for contraventions involving loans or deposits under sections 271D and 271E were dismissed because the filing delays, reported as 427 and 433 days, lacked satisfactory explanation. No substantive determination was made on the requirement for the reassessment Assessing Officer to record satisfaction during reassessment proceedings.

Appellate review of an advance ruling under Sections 100(1) and 101(1) is confined to the ruling and the factual record on which it was issued. It does not permit a fresh classification determination based on a materially altered product, revised packaging, or evidence produced only after the original ruling. Where a later test report lacks batch, manufacturing, or other particulars connecting the tested sample to the original product, it cannot establish product identity or equivalence. Classification of the subsequently presented product therefore cannot be determined through that appeal.

Admission of an appeal concerning GST penalties is raised in relation to whether payment of a pre-deposit is required. Respondents have been directed to file counters within four weeks, and the matter will be listed thereafter. No determination on the pre-deposit requirement or the merits of the penalty appeal is recorded.

Unappealed GST advance rulings remain binding on the applicant and jurisdictional officer unless altered through statutory appeal, rectification, or voidness procedures. An administrative circular cannot retrospectively displace such a ruling or prescribe a GST rate contrary to the applicable rate notification; GST must be imposed through notification, not circular. Challenges absent from the show-cause notice and authorised appeal grounds cannot be introduced at the second-appellate stage. Refund objections based on supplier entitlement or unjust enrichment likewise cannot be raised outside the notice, particularly where the recipient bore the tax incidence, provided the prescribed certificate, reversed input tax credit, and met statutory refund-payment conditions.

Rules 10 and 24 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025 permit rejection of an appeal when notified defects remain unrectified after scrutiny. The Tribunal's inherent powers may also be used to secure the ends of justice and prevent abuse of process. Continued non-appearance, failure to cure defects despite repeated opportunities, and absence of explanation may establish abandonment of appellate proceedings. A defective appeal may therefore be rejected without any determination of its underlying merits.