For assessment year 2018-19, exemption under Section 10(23C)(iiiad) applied by testing the annual receipts of each educational institution separately. Receipts of multiple institutions run by the same society could not be aggregated merely because their collective receipts exceeded the prescribed limit. The later amendment effective from 1 April 2022, which requires aggregation at the level of the person running multiple institutions, did not apply to that assessment year. Each institution remaining below the prescribed limit therefore qualified for exemption.

Reassessment jurisdiction under Sections 147 and 148 requires recorded reasons based on correct and verified foundational facts. A recorded premise that no return was filed is unsustainable where the return, its acknowledgement, and a refund issued on its basis are already on record. Making a cash-deposit addition without considering returned income further demonstrates non-application of mind. On these facts, the reassessment notice, consequential proceedings, and best-judgment assessment were void ab initio for invalid assumption of jurisdiction.

Search-based assessment founded entirely on material seized from another person falls within the special regime under Sections 153A and 153C, which overrides regular reassessment under Sections 147 and 148. Where seized material belongs or relates to a person other than the searched person, proceedings must be initiated under Section 153C after its statutory conditions are met. Sections 147 and 148 remain available for regular reassessment and matters not based on incriminating search material. Without distinct material outside the search, reopening under Sections 147 and 148 is legally untenable.

Employees' contributions to provident fund and ESIC deposited after the due dates under the relevant welfare laws are not deductible under section 36(1)(va), even where payment occurs before the income-tax return filing date; section 43B does not extend that benefit to employees' contributions. From AY 2017-18, ICDS VI requires exchange differences on specified forward contracts hedging export receivables to be recognised on settlement. Accordingly, a year-end marked-to-market gain recorded under AS-11 on unsettled hedging contracts is excluded from taxable business income where the entry is reversed and the actual gain or loss is recognised upon settlement.

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.