Binding precedent requires statutory set-off of brought-forward unabsorbed business losses after verification and in accordance with law. A pending Revenue challenge to an earlier appellate direction does not displace that obligation unless a higher appellate forum reverses the direction. In the absence of material establishing prior compliance or any infirmity in the direction, the Assessing Officer must give effect to the statutory set-off if it has not already been allowed.

Verification of sale agreements reconciled reported flat sales, so an addition based on AIR information and the percentage completion method was deleted. A 1% project interest recorded in audited financial statements was not unexplained investment under Section 69B, sustaining deletion of that addition. For alleged non-genuine purchases under Section 69C, only the profit element was estimated at 12.5% of the impugned purchases, and restriction of the addition to that extent was sustained.

Reassessment for AY 2014-15 cannot proceed where the original notice under Section 148 was issued after the limitation prescribed by the first proviso to Section 149. A time-barred and invalid notice cannot be deemed to be a notice under Section 148A(b), despite a subsequent order under Section 148A(d). Where commodity transactions and broker receivables were disclosed in the accounts and return, the record does not establish income escaping assessment represented by an asset exceeding the statutory threshold. The reassessment initiation was therefore invalid.

Cash deposits made during the demonetisation period require verification against month-wise cash sales, bank deposits and VAT returns before they can be treated as unexplained money. Where those records indicate a stated source, audit reports and Forms 3CA and 3CD must also be examined to determine the validity of both the unexplained-money addition and net-profit estimation. Fresh verification by the Assessing Officer, after providing an opportunity of hearing, is necessary before adjudicating these issues.

Prior sanction from the authority specified under Section 151 is a jurisdictional precondition for reassessment notices issued after three years from the end of the relevant assessment year, where the alleged escaped income exceeds the prescribed threshold. Approval must then come from the statutorily designated senior tax authority. The transitional relaxation does not dispense with that requirement. Notices approved by an incompetent authority are void ab initio, and consequential reassessment proceedings are invalid.

Cash receipts claimed as gifts require reliable evidence establishing the gift's genuineness, the donor's financial capacity, and the availability and retention of cash at the relevant time. A donor certificate and land-sale particulars were insufficient where sale proceeds arose after the last alleged gift and no evidence established cash withdrawals or the manner in which the donor or recipient held the cash. The claimed cash gift was therefore not satisfactorily explained and was treated as unexplained income.

Registered educational trusts with subsisting registration under sections 12A and 12AA retain their trust status for section 11 purposes. Assessment and appellate authorities cannot treat fee-charging educational activity as non-charitable by disregarding that registration; scrutiny of compliance with statutory requirements falls to the Commissioner. On that basis, denial of section 11 exemption and the related addition is unsustainable.

Reassessment for assessment year 2015-16 initiated by a notice issued on or after 1 April 2021 falls outside the limitation period under section 149, notwithstanding the relaxation provisions under the 2020 Act. Where the initial notice was issued on 7 April 2021 and later treated as a section 148A(b) notice, the consequential section 148A(d) order and section 148 notice are invalid as time-barred. The Revenue's recorded concession required such notices to be dropped.

Form 26A prevents a payer from being treated as an assessee in default for interest payments where the payee filed its return, included the income and paid tax; the corresponding disallowance is unavailable for substantiated payments. Payments characterised as purchases of spare materials do not by themselves attract tax deduction at source, but require verification of their factual nature. Machine-hire disallowance requires payment-wise proof that no tax deduction liability arose or that recipients discharged tax liability. For cash credits, creditor identity, creditworthiness and transaction genuineness, supported by financial records, banking trail, repayment and confirmation, negate an unexplained-credit addition.

Section 33(5) of the Insolvency and Bankruptcy Code bars institution of suits or other legal proceedings against a corporate debtor once a liquidation order is made. Income-tax assessment proceedings and consequential additions initiated or sustained against a company undergoing liquidation are therefore legally unsustainable under that statutory bar. Assessments and additions affirmed in appeal against the corporate debtor were treated as void ab initio and quashed.

Registration under Sections 12AB and approval under Section 80G for eligible charitable institutions cannot be qualified as tentative merely because a challenge to the governing jurisdictional High Court judgment is contemplated or pending. That judgment remains binding on authorities within its jurisdiction unless stayed, modified, or reversed by a competent forum. No statutory mechanism permits registration, approval, or their consequential benefits to be made conditional on speculative future proceedings. Caveats linked to a proposed Supreme Court challenge are legally unsustainable and must be deleted, leaving the registration and approval operative without qualification.

RELIEF Sub-Committee is constituted under the Export Promotion Mission to improve fund utilisation and uptake of the Support for Indian Exporters, Resilience & Logistics Intervention for Export Facilitation. It must review implementation of RELIEF's three components, including claims processed and available balances, examine factors affecting uptake and utilisation of approved funds, and recommend improvement measures. Recommendations are placed before the EPM Steering Committee for decisions concerning review of RELIEF, while the EPM Section acts as the Sub-Committee's secretariat.

GST rate rationalisation contemplates a simplified structure centred on 5% and 18%, with exempt supplies and a 40% special rate for identified luxury, sin and demerit supplies. The framework seeks to correct inverted duty structures, reduce classification disputes, align rates on akin goods and simplify compliance. The Council also accorded in-principle approval to a simplified GST registration framework for small suppliers selling goods inter-State through electronic commerce operators, subject to safeguards and detailed Law Committee recommendations. Compensation cess restructuring, individual life and health insurance exemptions, retail sale price-based tobacco valuation and improved IGST settlement processes were also addressed.

Section 194A(3)(v) separately addresses interest paid by a co-operative bank to a member and interest paid by a co-operative society to another co-operative society. The exclusion of co-operative banks is confined to the member-payment limb; a co-operative bank remains a co-operative society for the inter-co-operative society limb. Paragraph 42.7 of Circular No. 19/2015 preserves non-deduction, including time-deposit interest, where the depositor is a co-operative society. Section 80P does not determine this withholding obligation.

Export licensing conditions for agarwood permit export of agarwood oil, agarwood chips and allied products through Lokpriya Gopinath Bordoloi International Airport, Guwahati, subject to applicable statutory and regulatory requirements. The CITES export permit requirement for CITES species continues, as do the prescribed export ports. Exporters need not furnish additional information, no-objection certificates or documents beyond the prescribed documentation.

Input tax credit under Section 16(2)(c) remains conditional on actual payment of tax to Government, but supplier non-payment or retrospective cancellation cannot by itself justify reversal. The recipient must establish eligibility through transactional evidence, while the proper officer must investigate the particular supply, disclose supplier-default and recovery material, apply the law applicable to the relevant period, and issue a reasoned, notice-bound determination. Supplier recovery status and protection against duplicate collection are material considerations.

The first proviso to section 129A(1) excludes Appellate Tribunal jurisdiction over an order under section 128A relating to goods imported or exported as baggage. The decisive issue is the order's connection with baggage, not disputes concerning confiscation, declaration, duty, personal effects, concealment, concession, or penalty. Articles carried by an international passenger in luggage or on the person may constitute baggage. Section 129DD provides revision before the Central Government, ordinarily within three months, subject to a further period on sufficient cause.

Pending statutory amendment, GST field formations must not make further arrests. Transit conveyances may be intercepted only on specific intelligence authorised in writing by an officer of at least Joint Commissioner rank. Inspection and detention generally depend on jurisdiction over the supplier or recipient; where neither falls within that jurisdiction, the conveyance must proceed and information be sent to the jurisdictional officer. Absence of both an e-way bill and origin or destination documentation permits inspection, detention or seizure irrespective of jurisdiction. Transit confiscation is prohibited, and show-cause notices cannot be issued below the aggregate threshold of Rs. 10,000.

Rule 89(4) attributes the value of zero-rated goods to the refund period in which export invoices are issued and goods are removed under bond or LUT, rather than the later period of physical export. Sections 12 and 31 support invoice-and-removal recognition of supply, while actual export remains essential to establish export status and sustain the refund. Shipping bills and export records verify the later export event and must correlate with relevant invoices. Where export is delayed or does not occur within the stipulated period, Rule 96A governs extensions, tax and interest consequences; a mismatch in invoice and physical-export dates alone does not exclude the value from zero-rated turnover.

Under the pre-amendment Section 148 framework, an Assessing Officer must provide recorded reasons on request and dispose of reopening objections through a separate, reasoned speaking order before commencing merits scrutiny. A return filed in response to Section 148 is processed as a Section 139 return, but a Section 143(2) notice starts scrutiny and cannot precede disposal of jurisdictional objections. A Section 142(1) inquiry notice is likewise a merits-stage step. Following service of an adverse objection order, no further reassessment action may be taken for four weeks, preserving judicial-review rights. Breach may invalidate premature notices and consequential reassessment action.