Under the project-completion method, income from sale of flats, including survey-disclosed on-money, accrues when sale deeds are executed and title transfers, not when advance consideration is received. On-money consistently offered in the respective registration years, including amounts covered by undertakings for subsequent years, receives corresponding treatment. Sustained additions require limited verification: amounts taxed in the relevant subsequent years must be deleted, while unoffered amounts may be assessed in the year under review, with no deferral beyond the undertaking period.

Related-party commission payments may be disallowed as excessive or unreasonable only where the payment exceeds the fair market value of services, the legitimate needs of the business, or the benefit derived. A payment to a specified related person does not itself justify disallowance. Commission benchmarks must be based on genuinely comparable businesses; comparison with an unrelated business model cannot establish excessiveness. Verification should address the actual services rendered and their commercial justification. Where no comparable material demonstrates that commission paid to a spouse's proprietary concern was excessive or unreasonable, disallowance of the expenditure is unsustainable.

Alleged bogus purchases may warrant a limited addition where banking payments and GST registration are unsupported by verifiable counterparties or contemporaneous records; only 3% of the disputed purchases remains added. Unexplained expenditure requires proof that the assessee actually incurred it and a nexus supported by invoices, payment trails, goods movement, or other independent evidence. Uncorroborated third-party statements and unilateral GST reporting do not establish such expenditure, so the accommodation-entry addition does not survive. Commission additions based only on presumption or estimation, without proof of payment or a financial trail, are also deleted.

Political-party donation deductions are unavailable when seized material and sworn statements establish an accommodation-entry arrangement, cash repayment after commission, and the taxpayer produces no rebuttal evidence. The statutory presumption concerning seized material and the evidentiary value of search statements support treating the contribution as non-genuine. Interest on borrowed capital claimed for house construction depends on proof of actual construction and loan use; a loan labelled personal may qualify only after verification of supporting evidence. Tax-credit and professional-tax adjustments must be given effect in accordance with law.

Reassessment jurisdiction under Sections 147 and 148 requires a reason to believe that taxable income escaped assessment based on correct and relevant facts available when jurisdiction is assumed. Where a registered sale deed already held by the Assessing Officer showed joint ownership, recorded reasons could not validly attribute the entire sale consideration to one owner. Acceptance of a lower ownership share during reassessment could not cure that initial factual defect. The notice and consequential reassessment proceedings were therefore void ab initio.

Unexplained expenditure and unexplained money additions require reliable evidence linking the alleged expenditure or funds to the assessee. Third-party entries alone are insufficient where the underlying seized material is not furnished, effective cross-examination is unavailable, and no independent corroboration-such as a cash trail, bank withdrawal, delivery record, stock discrepancy, or confirmation-establishes incurrence, possession, or ownership. Presumptive income disclosure does not by itself validate an alleged unrecorded purchase. On this evidentiary approach, additions under sections 69C and 69A, together with consequential tax and penalty consequences, lack a sustainable foundation.

Reassessment initiated beyond four years requires a reasoned belief that income escaped assessment because the taxpayer failed to make a full and true disclosure of material facts. Third-party search information adopted without independent enquiry or a direct nexus to the taxpayer's records does not meet that jurisdictional threshold; the reassessment was therefore quashed. Section 69C requires proof that unexplained expenditure was actually incurred. Where export receipts were supported by contemporaneous business, customs and banking records, uncorroborated third-party material without effective cross-examination could not establish cash payments or unexplained expenditure. The addition was deleted, avoiding double taxation of recorded export receipts.

Appellate review must decide on the merits a disallowance arising from an assessment order; the existence of a separate additional claim does not justify refusing to determine that challenge. The disallowance therefore requires fresh merits adjudication by the Tribunal. Conversely, a fresh bad-debt claim first raised before the first appellate authority cannot be entertained where it neither arises from the reassessment nor falls within the scope of the underlying revision proceedings. That additional claim is unavailable in those appellate proceedings.

Banking companies governed by the Banking Regulation Act, 1949 fall outside the minimum alternate tax regime under Section 115JB. Leave-encashment liability may accrue under the mercantile system, but Section 43B(f) defers its tax deduction until actual payment to the employee. UPS qualifies for depreciation at the computer-equipment rate where it forms an integral part of the computer system and lacks independent functional use. Accordingly, minimum alternate tax does not apply to the banking company, leave-salary provision is deductible only on payment, and UPS receives computer-equipment depreciation.

Final assessment is unsustainable where a timely uploaded adjournment request is not considered because of a system-related inwarding delay. Natural justice requires a meaningful opportunity for the assessee to respond before finalisation. Portal records showing that the request was filed within the compliance period, but was not placed before the Assessing Authority, negate the premise that no response was filed. Proceeding with assessment without considering that request or affording an effective hearing breaches procedural fairness.

Statutory appellate remedy does not necessarily preclude writ scrutiny where an asserted breach of natural justice affects the assessment process. Faceless assessment procedures must comply with audi alteram partem: the taxpayer must receive reasonable time to answer a proposed adverse addition, and timely submitted replies and supporting material must be considered. Providing less than three working days and proceeding on an assumption of non-compliance despite acknowledged email submissions vitiates the assessment. Reconsideration must follow a reasonable hearing and consideration of the materials already furnished.

Determinate trust taxation under section 164 concerns measures intended to close tax-avoidance loopholes involving private trusts. The central legal issue is the validity of CBDT Circular No. 13/2014, which addresses the tax treatment of determinate private-trust arrangements under section 164 and the use of such structures for tax avoidance.

Supreme Court declined to interfere with the High Court's impugned ruling after considering the petitioner's submissions and record. The special leave petition was dismissed, and pending applications were disposed of. No underlying income-tax issue, statutory provision, or substantive legal principle is identified; the disposition rests solely on the absence of grounds for intervention.

Electricity subsidy computed as a percentage of energy charges incurred after production begins is a revenue receipt where it directly reduces manufacturing power costs. The purpose test governs characterisation: the scheme's object and operative mechanism prevail over the timing, source or form of payment. Although intended to promote industrial growth, the subsidy was limited to the post-production period and was neither linked to capital investment nor earmarked for asset acquisition, construction, capital-borrowing repayment or business expansion. It therefore provides operational assistance in carrying on business and is chargeable to tax as revenue income.

Assignment for consideration of leasehold rights in land and buildings allotted by an industrial development corporation is treated as a transfer of benefits arising from immovable property. Such assignment falls outside taxable supply under the GST framework governing transactions in immovable property and therefore does not attract GST. The applicable jurisdictional precedent remains binding because it has neither been stayed nor recalled, supporting non-levy on transfer to a third-party assignee.

Under the Uttar Pradesh GST Act, the monetary-limit policy for departmental litigation binds the Department. For GSTAT appeals, the prescribed threshold applies unless a specified exception is established. Commissioner authorisation to file an application does not override that policy. Where the disputed amount falls below the threshold, a departmental appeal is not maintainable unless the Department specifically pleads and proves a recognised exception, including a recorded case-specific opinion under the residual exception.

Tax and penalty demands under Section 74 based on an allegation that a registered firm is bogus or non-existent require proof of tax evasion. A valid GSTIN, identifiable business premises, and filing of GSTR-1 and GSTR-3B for the relevant period supported the firm's registered taxable status. The absence of goods at the premises during verification, without evidence that the firm was non-existent or had evaded tax, did not substantiate the allegation. The tax and penalty demand was therefore unsustainable.

Departmental GST appeals before GSTAT must comply with the binding monetary-limit policy issued under the Uttar Pradesh GST Act. Where the dispute concerns only penalty, the disputed penalty is the relevant amount for applying the prescribed threshold. The Revenue must specifically plead and establish a listed exception to maintain an appeal below that threshold. Statutory authorisation to institute an application does not itself displace the monetary-limit requirement or prove an exception. In the absence of evidence of a specified exception or a recorded Commissioner opinion under the residual exception, the appeal is not maintainable for merits adjudication.

Credit notes reduce taxable turnover under section 34 only when validly issued and declared within the statutory time limit. For inverted-duty-structure refund calculations under Rule 89(5), credit notes relating to supplies in the relevant refund period may reduce adjusted total turnover. Credit notes connected with earlier financial-year invoices but issued after the applicable declaration deadline cannot be excluded from adjusted total turnover. Refund eligibility must therefore be calculated without reducing turnover for those time-barred credit notes, and any resulting excess refund is recoverable.

Credit notes issued for returned, rejected, or reduced-value supplies reduce taxable turnover and may be deducted from adjusted total turnover under the accumulated input tax credit refund formula. Deduction is available where credit notes relate to invoices within the refund period. Credit notes issued during that period but relating to invoices from an earlier financial year cannot reduce adjusted total turnover if issued after the statutory deadline for declaring them. After excluding those belated notes, the recomputed maximum refund still exceeded the refund claimed, leaving the claim admissible.