Section 153D prior approval for search assessments requires the approving authority to independently examine draft assessment orders, assessment records and relevant search material for each assessment year. A composite approval issued without evidence of record movement, separate year-wise consideration, reasons or verification indicates a routine and mechanical exercise rather than informed statutory approval. Approval granted in this manner is invalid for want of application of mind, and assessment orders founded on it are vitiated and liable to be quashed.

In an unabated assessment under Section 153A, additions require incriminating material found during the search and a link between that material and the proposed addition. An unsecured-loan addition lacking that nexus is unsustainable. Alleged unexplained-expense additions are likewise unsustainable where seized entries are reconciled with agreements and books, verification reveals no adverse discrepancy, and the transactions represent genuine accounted business dealings. These principles support deletion of additions founded on recorded expenses or loans unconnected with incriminating search material.

Transfer-pricing benchmarking under the Transactional Net Margin Method requires a disclosed, reasoned functional, asset and risk analysis to support comparable-company exclusions and selections across distribution, software-development and technical-support segments. Absent that analysis, comparability determinations require fresh, transparent evaluation with an opportunity to submit evidence. Deferred payment or receivables exceeding the agreed credit period constitute a separate international transaction, because only credit within that period is embedded in the sale price. Foreign-currency delayed receivables require separate interest benchmarking at LIBOR plus a 200-basis-point spread.

Brand-development outlays incurred in an existing business are revenue expenditure where they support the profit-earning process and create no capital asset; commercial expediency cannot be displaced without evidence of non-business purpose. Additional deduction claims may be considered in appellate proceedings, and accrued redemption premium on transferable zero-coupon debentures is deductible where no identifiable payee gives rise to withholding obligations. Corporate guarantees require a service charge but are not benchmarked as bank guarantees; a 0.2% fee reflected limited benefit. Aircraft treated as aeroplanes qualify for 40% depreciation. Investment shares consistently held as investments and sold through limited delivery-based transactions generate capital gains, supported by consistency of past treatment.

Freight income from operating ships in international traffic qualifies for exemption under Article 8 of the India-Singapore tax treaty where eligibility is undisputed. Where such income was offered under section 44B because the return form did not permit a direct treaty-exemption claim, relief under section 90 must be granted. An incorrect treaty-country code in the original return cannot justify denial when a revised return corrected the code to Singapore but was not processed. Relief is to be granted for eligible income after an opportunity of hearing.

Penalty for failure to obtain an audit under Section 44AB cannot be sustained where the assessee proves reasonable cause under Section 273B. Dependence on a person responsible for business and regulatory compliance, that person's death, and the assessee's disability and resulting inability to manage the business showed that the default was neither deliberate nor lacking in bona fides. These circumstances constituted reasonable cause, making the penalty for audit non-compliance unsustainable.

Charitable exemption may not be denied in return processing solely because Form No. 10B was filed after the prescribed date where the audit report was available before the intimation. The filing deadline for the audit report is treated as procedural and directory in those circumstances, with timely availability before processing constituting substantial compliance. The condonation route for delayed filing operates as an additional remedy and does not exclude appellate review of an adjustment to the exemption claim. Consequently, refusal to condone delay need not prevent appellate consideration or acceptance of the exemption claim.

Jurisdictional objections to reassessment may be raised collaterally in an appeal against revision under section 263 because revision presupposes a legally valid assessment order. A defect in the authority to initiate reassessment cannot be cured by waiver, acquiescence, participation, or failure to challenge the reassessment directly. Where more than three years have elapsed, section 151(ii) requires sanction from the Principal Chief Commissioner or Chief Commissioner; approval by the Principal Commissioner under section 151(i) does not meet that condition. Reassessment without competent sanction is void ab initio and cannot support revisionary jurisdiction under section 263.

Reassessment notices issued in a deceased assessee's name lack jurisdiction where death preceded their issuance. Failure by legal representatives to inform tax authorities of the death does not validate proceedings against a non-existent person. Section 159 permits continuation only of proceedings validly initiated during the assessee's lifetime against legal representatives. This defect is jurisdictional, not procedural, and cannot be cured under Section 292B; the notice, order under Section 148A(d), and consequential reassessment proceedings are void ab initio.

Genuine COVID-19-related non-appearance justified setting aside the ex parte appellate order and restoring the matter to the Tribunal. As the Tribunal is the final authority on facts and law, principles of natural justice required a fresh hearing. The merits and questions of law remained open for adjudication, with the assessee to be heard before a fresh decision.

Statutory priority for a registered secured interest gives a prior mortgagee first charge over later income-tax attachments; those attachments cannot displace the secured debt. Registration law does not empower a Sub-Registrar to delete attachment entries already shown in encumbrance records. Priority should instead be implemented through a contra entry identifying the secured creditor's precedence, while preserving the attachment record and allowing any surplus sale proceeds, after satisfaction of the secured debt, to be applied towards the attachment.

Revision under Section 263(1) requires both an erroneous assessment order and prejudice to Revenue; a different possible view does not justify revisional jurisdiction. Where the Assessing Officer examines allegedly bogus steel-scrap transactions, verifies the relevant material, and disallows the related loss, the assessment reflects an informed and legally plausible view rather than lack of inquiry. Revision is therefore unavailable on those facts, and no substantial question of law arises.

Rule 3(d) is amended by replacing "State Government/Union Territories" with "Central Government/State Government/Union Territories." The change adds the Central Government to the governmental entities expressly named in the provision while retaining State Governments and Union Territories. The amendment is confined to the institutional description in rule 3(d).

Unregistered investment advisory services are prohibited under the SEBI Act and the Investment Advisers Regulations. Where advisory services were admittedly provided without registration, the activity was unlawful and fees collected through it were refundable to all affected clients. The refund obligation was not limited to investors who had submitted individual complaints, as the unlawfulness attached to the unregistered activity and the fees collected from every client through that activity.

Interception, monitoring and decryption safeguards are amended by replacing "security agency" in rule 23(1) with "competent authority and the security agency". The provision therefore covers the competent authority alongside the security agency. The amendment takes effect upon publication in the Official Gazette.

Interception, monitoring and decryption of information in computer resources require a reasoned direction by the competent authority, issued only where other reasonable means cannot obtain the information. Emergency action requires written intimation and competent-authority approval, failing which the activity must cease. Directions must identify the targeted information or persons, name the officer authorised to receive the information, remain time-bound, and be subject to review. Authorised agencies, intermediaries, persons in charge of computer resources and decryption key holders must provide specified assistance, maintain records and preserve secrecy; use and disclosure are confined to investigation, authorised security-agency sharing and judicial proceedings.

Statutory appeals must be filed within the prescribed two-month limitation period, with delay condonable only for a further 30 days. An appeal filed after both periods is time-barred and may be declined. Acknowledged service of the original order, a reply to the show-cause notice, and participation in the personal hearing support the conclusion that procedural opportunity was available. A substantially delayed writ petition does not ordinarily warrant discretionary relief against rejection of such an appeal.

GST refund claims may bundle successive tax periods across financial years. Accumulated input tax credit refunds under an inverted duty structure exclude identical input and output goods affected only by a later rate reduction. For non-zero-rated and non-deemed-export tax refunds, cash and electronic credit ledger components must be returned in their original proportions, with the credit component re-credited through FORM GST PMT-03. Accumulated input tax credit refunds are restricted to supplier-furnished invoices reflected in FORM GSTR-2A, and Annexure B requires HSN/SAC details where stated on inward invoices.

Foreign-currency loans advanced to overseas associated enterprises require an economically comparable arm's-length benchmark; LIBOR-linked rates are appropriate where the loans are received and used abroad, unlike Indian corporate-bond yields. A royalty CUP comparison requires materially comparable uncontrolled transactions, including comparable territories, trademarks, products and market conditions; an undisplaced TNMM analysis supports the existing royalty treatment. Recurring market research for established products remains revenue expenditure where it creates no identifiable capital asset, and unsupported ad hoc expense disallowances are not sustainable. For industrial-undertaking deductions, manufacturing by-product and scrap sales satisfy the direct-nexus requirement, whereas machinery lease rent does not.

Jurisdiction covers Chapter IX contraventions within the officer's State or Union Territory, with the location of the computer system or network determining where a complaint is made. Complaints use the prescribed form and a fee linked to compensation claimed. Respondents may plead guilty or show cause, while the officer may dismiss the matter or conduct inquiry after considering reports, evidence and submissions. Electronic records may be relied upon, and matters disclosing offences requiring punishment rather than financial consequences must be transferred for criminal jurisdiction.