For reassessment proceedings, a return filed after the period stated in a notice under Section 148 remains valid where the law applicable to the assessment year permits its filing; it cannot be treated as non est merely because it was delayed. Once that return and the required materials are furnished, service of a scrutiny notice under Section 143(2) is mandatory before reassessment can be completed. Completion of reassessment without issuing or serving that mandatory notice is invalid.

Section 220(6) permits consideration of a stay of disputed tax demand while an appeal is pending. An unconditional stay of the full disputed demand was warranted because the stay rejection failed to address material grounds, including a prima facie limitation challenge to the reassessment notice. The unresolved limitation issue remained for appellate determination. The assessment was high-pitched, with additions nearly five times returned income, and turnover alone did not establish financial soundness.

Approval for reassessment under section 151 requires genuine consideration of the assessee's response to the section 148A(b) notice. Recording that no response was filed when a response existed, and sanctioning reassessment solely on the Assessing Officer's proposal and materials, constitutes mechanical approval without application of mind. Such invalid approval renders the consequential order under section 148A(d) and notice under section 148 unsustainable, while leaving fresh proceedings available in accordance with law.

Interim protection against recovery of a refund credited to the petitioner's bank account was granted pending writ adjudication. The Department had sought direct recovery from the bank based on the Assessing Officer's satisfaction. To balance equities, the existing fixed deposit was required to remain intact pending further orders. Amendment of the writ petition was permitted, and the matter was listed for further hearing.

Faceless assessment procedures require a personal hearing when specifically requested under section 144B(6)(viii) of the Income-tax Act. The applicable SOP also requires at least seven days to answer a final show-cause notice, unless a limitation-driven curtailment is justified. Denial of the requested hearing and unexplained curtailment of the response period breach natural justice and permit judicial review under Article 226. The assessment order, demand notice, penalty show-cause notice, and consequential penalty order were set aside as invalid.

Prima facie jurisdictional objections to reassessment, including sanction and statutory limitation, supported interim protection while the pending appeal remained undecided. Because 20% of the disputed demand had already been deposited, recovery was limited to that amount: adjusted refunds exceeding the deposit were to be returned, and further refund adjustment was barred pending appellate disposal. The appellate authority was required to determine the appeal within 12 weeks.

TNMM comparability depends on functional, asset and risk profiles; entity size may justify a turnover filter even without a prescribed ceiling. Operating-margin analysis may use a cash PLI excluding depreciation where asset types, technology and investment levels cause material depreciation differences. Provisions for bad and doubtful debts ordinarily form operating costs unless demonstrated to be extraordinary. Equipment supplied without charge by an associated enterprise does not constitute a taxable business perquisite where ownership remains with that enterprise, the recipient neither capitalises nor depreciates it, and its use is limited to testing software for the owner.

Section 119(2)(b) provides a statutory remedy to seek condonation for delayed return filing where the appellate authority has no such power. Completion of assessment and pendency of an assessment appeal do not, by themselves, bar that remedy. Genuine hardship requires a liberal assessment of a delay explanation, particularly where a short COVID-19-period delay is substantially similar to a previously accepted delay. Rejection solely on the basis of completed assessment or pending appeal is unsustainable, and the related deduction claim requires consideration on merits in accordance with law.

Absence of an effect-giving order and continued seizure of a locker require prompt administrative consideration while the petition remains pending. The Assessing Officer must provide a personal hearing and issue appropriate effect-giving orders within the stipulated period. Arrangements must also be made to open the seized locker and prepare an inventory of its contents. No final determination has been made on tax liability, refund entitlement, or release of the seized articles; the matter remains listed for further hearing.

Prior approval for an order under Section 148A(d) and a reassessment notice must be obtained from the authority prescribed by the elapsed period from the end of the relevant assessment year. The temporary extension allowing approval by the authority applicable within three years, where that period expired during the 2020 relaxation regime, operated only until 30 June 2021. Approval obtained in July 2022 from a Principal Commissioner did not satisfy the requirement applicable after that period; approval from the higher authority under Section 151(ii) was required. Absence of approval from the statutorily competent authority invalidates the order, notice, and resulting reassessment proceedings.

Assessment validity was questioned where it was issued on a PAN allegedly neither obtained nor used by the petitioner. Material differences between two PAN records, including date of birth and addresses, left unresolved how substantially similar PANs were issued and why one was later deactivated. Original PAN application records, verification material, profile details, and deactivation records were required to be produced for further examination. No final determination was made.

Section 264 revision requires the Commissioner to examine an assessee's grounds and supporting material on merits, even where the assessee did not participate in reassessment proceedings. The Commissioner may call for records and make or direct inquiries, but must pass an order not prejudicial to the assessee. Non-compliance with reassessment notices does not remove the duty to give reasoned consideration to the revision claim. Rejecting revision through a bare assertion that the assessment order is well reasoned, without addressing submissions, is a non-speaking and unsustainable exercise of revisionary jurisdiction.

Under the pre-1 April 2021 reassessment framework, a return filed in response to reopening is treated as a return under Section 139, with scrutiny initiated through Section 143(2). Recorded reasons must be supplied on request, and reopening objections must first be resolved by a speaking order because they may challenge jurisdiction to reopen. Assessment cannot proceed through a scrutiny notice or a Section 142(1) information notice until that disposal. Following rejection of objections, a mandatory four-week interval must elapse before further reassessment action, preserving the taxpayer's opportunity to challenge the rejection.

Monetary-limit policy for Revenue litigation before the High Court applied to appeals arising from revision proceedings; the claimed exception did not automatically require disregard of tax effect. Because the tax difference was substantially below the applicable policy threshold and the transactions showed no recurring or multiple disputes, the appeals were dismissed as below the monetary limit. The questions of law remained open.

Disallowance of expenditure under section 14A where no exempt income is earned was the central issue. The Supreme Court declined to interfere with the High Court's application of an earlier unchallenged High Court ruling and dismissed the special leave petition. Revenue expenditure incurred as compensation for tenancy rights was also identified as part of the dispute.

Failure to cure fundamental and technical defects notified by the Registry through the online filing portal rendered the appeal liable to rejection as defective. Despite repeated effective opportunities to rectify the objections, the appellant neither appeared nor took corrective steps. Procedural compliance required rectification of the notified filing defects within the opportunities provided.

Expiry of an e-way bill, by itself, is a procedural or documentary lapse and does not sustain a penalty for movement of goods where no independent evidence establishes an intention to evade tax. Valid tax documents, interception near the declared destination, and absence of discrepancies in the goods or underlying transaction weigh against penalty. Diversion of goods, fictitious transactions, suppressed tax liability, or other deliberate evasion must be supported by material evidence.

Uncured registry defects in a GST appeal may warrant dismissal at the threshold where the appellant fails to rectify them despite the opportunity available. Failure to address the defects can indicate inadequate attention to the appeal, particularly where the appeal appears meritless. Further time to cure procedural defects need not be granted when it would not serve the interests of justice. The appeal was therefore treated as liable to dismissal without allowing an additional opportunity for rectification.

GSTR-1/GSTR-3B mismatch alone does not establish short-payment of GST; differential figures require reconciliation with returns, electronic records, payment particulars, annual returns and other relevant material. Where a demand includes input-tax-credit reversal under Rules 42 and 43, its statutory basis and computation must be separately identified and established. Ex parte appellate proceedings may continue after valid hearing opportunities, but a reasoned determination remains necessary for pleaded claims concerning rectification, subsequent payment, interest, penalty, communication, duplication and statutory waiver. Appellate affirmation without reconciliation and examination of these material claims is legally unsustainable.

Penalty under Section 129(3) for goods in transit requires a legally established contravention supported by cogent and reliable evidence. Where goods are accompanied by a tax invoice and e-way bill and no quantity or quality discrepancy exists, an inconsistency in the address or business particulars alone does not establish mens rea or an intention to evade tax. Such a technical or procedural breach cannot justify penal action without independent proof of tax evasion. The penalty and the appellate order sustaining it were unsustainable for insufficient evidence of a penal contravention.