Rule 46A permits admission of material additional evidence where a filed application and supporting affidavit establish its relevance to disputed audit and accounting findings. Rejection of books of account does not justify ad hoc profit estimation; any estimate requires a rational comparative or historical basis, including prior gross-profit or net-profit results. Cash deposits supported by cash-book entries, regular business receipts and prior withdrawals cannot be treated as unexplained merely because they were deposited in instalments during demonetisation. Section 68 applies to sums credited during the relevant year, not to an opening trade-creditor balance reclassified as an unsecured loan without any fresh receipt or credit.

For the section 54F residential-house ownership condition, a property held by a company remains the company's property because of its separate legal identity; a director cannot be treated as its owner solely on that basis. A jointly held flat may be counted as the taxpayer's residential house, but, on the stated facts, it remained the only such house apart from the property receiving the qualifying investment. The ownership condition was therefore met, making the capital-gains deduction available.

Section 14A disallowance does not arise where no exempt income is earned and, where exempt income is earned, cannot exceed that income. Electrical installations qualify for 15% depreciation, while UPS, as a computer accessory or peripheral, qualifies for depreciation at the computer rate. Bank guarantee fees paid to banks are not commission under section 194H and do not trigger tax deduction at source or disallowance under section 40(a)(ia). Substantial interest-free funds support a presumption that capital work-in-progress was financed from those funds absent a borrowing nexus. For section 80IC, separately accounted unit losses not disclosed as income-tax losses cannot reduce the deduction; allocation of common expenses requires fresh examination.

Employees' provident fund and employee state insurance contributions credited on the next working day after Saturday and Sunday bank holidays remained allowable as deductions. The payments were cleared and deposited on 17 June 2019, and the timing did not result from an intentional default. Disallowance of the employee-contribution payments was therefore unsustainable.

Belated furnishing of the audit report in Form No. 10B does not by itself disentitle a charitable trust from exemption under sections 11 and 12 where the report was obtained before the return was filed. The filing requirement is procedural and directory, not mandatory, when substantial compliance exists. Denial of the statutory exemption solely because the prescribed audit report was furnished late is therefore unwarranted, particularly where equivalent exemption claims were accepted in adjacent assessment years. The exemption claim under section 11 was consequently allowed.

Section 270A distinguishes ordinary under-reporting from under-reporting caused by misreporting. Cash deposits disclosed through a revised computation, with consequential tax paid and the computation accepted in assessment, do not establish misreporting unless the applicable limb of section 270A(9) and its ingredients are identified. Where the taxpayer does not contest the addition and timely seeks immunity after paying tax and interest, the disclosure may constitute under-reporting at most. A penalty calculated for misreporting is therefore unsustainable, and immunity from penalty is available.

Sufficient cause for delayed filing requires an evidence-based assessment of the assessee's bona fides, conduct, alleged professional default, timing of discovery and promptness of subsequent action. Valid electronic service under Rule 127 starts limitation but does not itself resolve whether sufficient cause existed. Reliance on a professional adviser cannot be accepted automatically or rejected merely because a company ordinarily bears its adviser's default. Each condonation application requires independent reconsideration after an effective hearing, allowing supporting affidavits, correspondence and other material. The merits of the assessment, addition and penalty proceedings remain open.

Uncorroborated electronic worksheets and screenshots cannot independently support income-tax additions where authorship, ownership and transactional nexus remain unproved and no independent verification is undertaken. On that basis, additions for alleged unexplained loans, related interest, cash purchases and debtor balances were deleted because the electronic records lacked supporting books, bank records, invoices, confirmations, stock records or third-party enquiries. Diary workings linked to business could support taxation only of the profit embedded in unaccounted sales; unsupported multiplication of recorded figures was rejected. Cash rent remained disallowed for want of verifiable payment and landlord evidence, while excess stock remained taxable as unexplained investment because no satisfactory reconciliation with book stock was furnished.

Insight Portal information may validly trigger reassessment enquiries where the taxpayer receives notice, the response is considered, and the record shows independent application of mind rather than mechanical reliance on departmental inputs. Documented share purchases and sales through recognised brokers and exchanges, supported by demat records, contract notes, bank statements and securities transaction tax, cannot be characterised as unexplained money or accommodation entries without evidence of cash dealings, fabricated records, or a link to entry providers. Uncorroborated investigation material and suspicion do not displace unrebutted transaction evidence; the reopening challenge failed, but the alleged bogus capital-gain addition was deleted.

Section 87A rebate is available to an eligible resident individual taxed under the concessional regime where total income remains within the prescribed threshold, including against income-tax on short-term capital gains taxable at special rates. Neither the rebate provision nor the special-rate provision expressly excludes such gains from the rebate. The express restriction applicable to certain long-term capital gains demonstrates that an exclusion operates only when specifically enacted. The concessional-regime provision does not independently limit the rebate, and a later proposed restriction applies prospectively rather than to the relevant assessment year.

Consistent treatment of depreciation is required when calculating operating profit to operating cost margins under the Transactional Net Margin Method. Including depreciation in the assessee's operating costs while excluding it from comparable companies' costs produces a non-comparable operating-margin analysis. On excluding depreciation consistently, the assessee's profit level indicator exceeded the arm's length margin and its operating revenue exceeded the computed arm's length price. The international transactions were therefore treated as being at arm's length, and the transfer-pricing adjustment was deleted.

Section 148A(b) requires that a person receive at least seven days to respond before reassessment proceedings are initiated. A notice allowing only five effective days, or six days including its issue date, fails to meet that mandatory minimum and invalidates the notice and reassessment founded on it. Where the reassessment addition is deleted because the proceedings are void from the outset, a penalty under Section 271AAC(1) that depends on that addition has no surviving basis and is unsustainable.

Section 69C additions for alleged bogus or unaccounted purchases require reliable evidence connecting the taxpayer to the expenditure. Uncorroborated parallel tally data recovered from a third party, without purchase invoices, delivery proof, payment evidence, transport records or independent verification, cannot by itself support such an addition where the taxpayer's contrary records remain unrebutted; the addition was therefore deleted. Reliance on third-party statements or seized material without allowing cross-examination or confrontation of underlying details also breaches principles of natural justice and independently undermines the addition. Unexplained-expenditure charges cannot rest solely on untested third-party search material.

Approval of a resolution plan under Section 31(1) binds all stakeholders, including governmental authorities, and extinguishes claims omitted from the approved plan. Where Revenue does not lodge its claim during the corporate insolvency resolution process, reassessment proceedings and consequential tax demands concerning the pre-resolution-plan period cannot be initiated or continued. Such unsubmitted tax claims do not survive resolution-plan approval, preventing further recovery action for the relevant period.

Reassessment may be initiated only on information suggesting that income chargeable to tax has escaped assessment. A GST adjudication order was not shown to constitute qualifying information under the applicable risk-management strategy. Proceedings under the Income-tax Act must therefore be undertaken independently and cannot rest solely on GST adjudication or the result of a related GST appeal. On the available preliminary record, the reassessment notice was not quashed; challenges to any resulting reassessment order remain available in accordance with law.

Reassessment following a completed scrutiny assessment is invalid where it revisits a share-sale transaction, valuation, purchaser credibility, genuineness and capital-gains exemption already examined and accepted after detailed inquiry. An assessment order need not record every query or reasons for accepting a claim; inquiry and acceptance establish formation of opinion. Reopening on the same material therefore constitutes a change of opinion. A new objection to an exemption claim that was not stated in the show-cause notice cannot support reopening, and recorded reasons cannot be supplemented through an affidavit or oral submissions. The reassessment notices and consequential proceedings were quashed.

E-invoicing for coaching supplies is mandatory where a notified supplier exceeding the applicable turnover threshold makes a genuine supply to a registered recipient. Recipient status depends on contractual liability to pay the consideration, assessed from enrolment and contractual terms; payment of fees or provision of a GSTIN alone does not establish that status. The supplier's e-invoicing obligation is independent of the recipient's intended business use or entitlement to input tax credit. Input tax credit remains governed separately, with the claimant bearing the burden of proving eligibility. Individual transaction genuineness, business-to-business classification, and credit entitlement remain open to examination.

Papad Khar, manufactured from sodium chloride, sodium carbonate and sodium bicarbonate, is classified by its composition, manufacturing process and functional character under tariff item 28362090, rather than as salt under Heading 2501 or yeast or prepared baking powder under Heading 2102. It is treated as an inorganic carbonate preparation taxable at 18% GST under the applicable Schedule II entry. Exemption available to finished papad does not automatically extend to Papad Khar as an input or processing ingredient. Inputs and finished goods require independent tariff classification and tax treatment, and Papad Khar does not fall within the claimed exemption entries.

Urgent GST appeal listing may be granted where sufficient cause justifies limited exemption from ordinary Registry scrutiny. Inherent procedural powers, urgent-matter procedures and early-hearing mechanisms support procedural relaxation to secure substantial justice, without dispensing with substantive statutory requirements. Continuing inability to conduct business following GST registration cancellation established the pleaded urgency. Urgent-hearing relief was granted and the main appeal was directed to be listed for admission.

Section 112(3) governs the time for filing an appeal before the Tribunal and does not impose a separate six-month limit on the Commissioner's review of a first appellate authority's order. The departmental appeal was filed within the applicable extended limitation period. The objection to its maintainability, based on alleged delay in the review order, was rejected, and the appeal was admitted for hearing on merits.