Banking tax computation addresses arm's-length remuneration, provisions, securities valuation, income recognition and statutory deductions. Technical and IT-enabled services supplied to associated enterprises require value-based arm's-length remuneration; where reliable contemporaneous comparables are unavailable, a 10% cost mark-up is reasonable. Actuarially valued pension and employee obligations arising from past service are accrued liabilities, but leave encashment follows the actual-payment requirement. Banking securities may be consistently valued at cost or market value, whichever is lower, and interest on non-performing assets is taxable only on realisation under the real-income principle. Foreign-branch income remains taxable in India with treaty relief. Deductions for standard-asset provisions, bad debts and eligible business income depend on statutory conditions and verified computations.

Penalty proceedings under section 271D, where no assessment or related order exists during which they were initiated, fall under the six-month limb of section 275(1)(c). The relevant financial-year limb does not apply in that situation. The show-cause notice issued under section 274 read with section 271D constituted initiation of penalty action at the latest. As the penalty order was issued after expiry of six months from the end of that month, it was time-barred, quashed, and the sustained penalty was deleted.

Interest awarded under a foreign arbitral award becomes part of a judgment debt once the award is declared enforceable under section 49 of the Arbitration Act and treated as a court decree. The interest component then loses its separate character as interest. Because the amount does not arise from money borrowed or debt incurred, it falls outside the Income-tax Act definition of interest. The treaty provision governing interest income is therefore inapplicable, and the decretal amount representing arbitral interest is not taxable in India.

TNMM benchmarking for a limited-risk distributor of licensed content should assess comparability through functions, assets, risks, contractual terms and reliable financial data; product differences alone do not render software or hardware distributors unsuitable comparables. Rejection of the examined comparables solely because they were outside the film or entertainment industry lacked identified material functional or risk differences. An Other Method revenue split requires comparable uncontrolled transactions, reliable market evidence, or an objective economic basis for allocation. Assigned FAR weightages cannot quantify economic value merely by identifying functions and risks. TNMM was applied for arm's-length-price recomputation, deleting the consequential transfer-pricing adjustment.

Section 92CA(1) confines a Transfer Pricing Officer's reference to determining the arm's length price of a specified international transaction under section 92C. It does not extend to determining whether a permanent establishment exists under Article 5 of the India-Singapore tax treaty, or whether and how business profits are taxable and attributable under Article 7; those issues remain for the Assessing Officer. Where remand required the Assessing Officer to re-examine permanent establishment after cross-examination and consideration of relevant material, a reference without an identified international transaction exceeded transfer-pricing jurisdiction. An assessment based solely on such findings, without independent verification by the Assessing Officer, was unsustainable.

Section 200A acquired express power to compute and demand late fee under Section 234E only from 1 June 2015, and that amendment operates prospectively. Consequently, an intimation under Section 200A cannot validly levy Section 234E late fee for delayed quarterly TDS statements relating to periods before that date. Where High Court decisions conflict on the issue, the interpretation favourable to the assessee applies. Late fee imposed for TDS statements pertaining to financial year 2012-13 was therefore not chargeable and must be deleted.

For property acquired through allotment, section 56(2)(x) requires stamp duty value to be determined as on the agreement or allotment date, rather than the conveyance-registration date, where consideration was paid through banking channels before registration. Formation records, trustee confirmation, a pre-existing bank account, developer confirmation and banking-channel payment supported the trust's existence and the booking advance before PAN incorporation. Because the stamp duty value on the relevant allotment date was lower than the purchase consideration, no addition for alleged excess stamp duty value was sustainable.

Section 80G(5B) treats an institution or fund whose religious expenditure does not exceed five per cent of total income as eligible for Section 80G. Approval under Section 80G(5) cannot be denied merely because a trust has religious objects where its objects are substantially charitable and serve the general public, without first determining whether religious expenditure exceeds that threshold. The restriction concerning benefits for a particular religious community or caste under Section 13(1)(b) is relevant to exemption under Section 11 rather than registration under Section 12A. The application requires verification of the applicable statutory conditions.

Section 80-IB(10) deduction requires a qualifying housing project to satisfy the minimum plot-area condition and prescribed residential-unit built-up area. Excluding land initially earmarked for the project and using it for a personal residence exceeding the permitted unit area removes that land from the qualifying project. Where the remaining project area falls below the statutory minimum, the deduction is unavailable for the relevant assessment years.

Assessment completed without considering the assessee's response to a show-cause notice, despite a prior direction to consider it, breaches the principles of natural justice. The limitation period does not excuse non-compliance with that direction or deny effective consideration of the response. Such an assessment is invalid and requires fresh assessment proceedings after due consideration of the reply.

The clean slate principle applicable to a corporate debtor acquired as a going concern in liquidation extinguishes past liabilities and investigations, preventing their imposition on the purchaser. Reassessment for alleged cessation of interest liability cannot rest on conjecture that interest was claimed as a deduction where records show no such claim after the account became a non-performing asset. The same alleged cessation cannot be repeatedly subjected to reassessment for earlier and later assessment years. Failure to address the clean slate defence and relevant statutory records rendered the reassessment notice and order invalid and liable to be quashed.

Reasoned Tribunal adjudication requires meaningful consideration of the parties' contentions and the issues arising from assessments. A common order disposing of seven appeals was procedurally irregular because it also covered separate sets of appeals heard and pronounced on different dates. The absence of reasons and apparent undue haste rendered the order unsustainable, requiring fresh and independent adjudication by a different Bench, with all merits remaining open.

Revenue's proposal to drop reassessment proceedings against the purchasing company rendered the reassessment notice and all consequential proceedings unsustainable, notwithstanding its reserved right to proceed against the seller company. The reassessment notice and resulting proceedings against the purchasing company were quashed, as the stated withdrawal left no basis for their continuation in law thereafter.

Exchange of information under tax treaties is considered in relation to the one-year extension of the assessment limitation period where foreign tax information is sought. The key issues are the scope of the India-Swiss Confederation treaty, reliance on the India-Hong Kong treaty's information-exchange provision, and whether the information relates to the relevant fiscal year. These matters determine whether assessment for the relevant assessment year can proceed within the extended limitation period.

Reassessment against an amalgamating company cannot continue after its successor has been assessed for the same income and assessment year. Assessing identical share application money in the amalgamated successor's hands treats that successor as the person liable following amalgamation. Parallel proceedings against the predecessor, which has ceased to exist, would expose the same income to duplicate assessment and taxation. The reassessment notice and consequential proceedings against the amalgamating company were therefore quashed, with the issue resolved in the assessee's favour.

Criminal prosecution for failure to deposit tax deducted at source cannot rest on an erroneous assertion that an individual was a company director. Principal-officer status and resulting criminal responsibility require an accurate factual basis. Where the show-cause notice, designation order, prosecution sanction, and complaint all rely on alleged directorship, and the Revenue accepts that the individual was never a director, that foundational error prevents prosecution of that person as the company's principal officer.

Assessment under section 153C concerned whether documents seized during search proceedings related to or pertained to the petitioners' undisclosed income. The Supreme Court found no ground to interfere with the High Court judgment and dismissed the special leave petition, leaving the High Court's treatment of the seized documents undisturbed.

Institutional bias is not established merely because a departmental appeal follows a superior officer's review order. The appellate officer exercises independent quasi-judicial authority, and departmental hierarchy alone does not show a real likelihood of bias without personal interest, animus, or direct prejudice. Section 74 penalties require concrete proof of fraud, willful misstatement, or suppression with intent to evade tax. Audit-detected input-tax-credit and transitional-credit discrepancies, where relevant records were available to the department, do not by themselves establish such intent. Tax and interest paid before the show-cause notice for those issues operate under Section 73(5), attracting the corresponding penalty immunity.

Section 74 of the CGST Act requires evidence that an input tax credit mismatch is linked to fraud, wilful misstatement or suppression of facts, with intent to evade tax. A discrepancy between Forms GSTR-3B and GSTR-2A alone, or a supplier's default, does not establish that nexus against the recipient. Where the recipient pays the ascertained tax and interest before issue of a show cause notice and culpable intent is not proved, the matter falls under Section 73. Invocation of Section 74 and imposition of penalty are therefore unjustified.

Rule 90(2) limits preliminary scrutiny of a GST refund application to its completeness under Rule 89. Refund classification, the applicability of prescribed statements, the evidentiary adequacy of proof of foreign inward remittance, and limitation cannot be determined through a deficiency memo at that stage. The contents and nature of a remittance document, rather than its title, must be evaluated during merits adjudication. A limitation objection also requires merits consideration after an opportunity of hearing. Refund applications must therefore be entertained on refiling, with these objections considered during substantive processing.