Section 153C jurisdiction requires a satisfaction note to identify how seized incriminating material relates to each relevant assessment year. Mere recording of a seized hard disk and a proposal to initiate proceedings for specified years, without a year-specific nexus, is insufficient. Proceedings initiated on such vague satisfaction are invalid, favouring the assessee.

Modified returns furnished after a business reorganisation, where no assessment or reassessment proceeding is pending, permit only modification of total income already determined to implement the reorganisation order. Such returns do not operate as returns under Section 139 capable of triggering fresh scrutiny under Section 143(2). Section 170A distinguishes completed assessments from pending proceedings: Section 170A(2)(a) applies to completed assessments, while Section 170A(2)(b) permits assessment or reassessment only where proceedings remain pending. Section 170A(3) does not expand jurisdiction. Verification may be limited to ensuring proper implementation, but de novo scrutiny and consequential transfer-pricing proceedings lack jurisdiction.

Section 10B deduction for an export-oriented unit should not be reduced through a blanket turnover-based allocation of expenditure where the unit maintains separate audited accounts, registration, factory facilities and production arrangements. Material differences in product mix, fixed assets, manufacturing process, power consumption, interest burden and tax incidence supported unit-wise expense allocation. In the absence of any identified discrepancy, and where profitability remained broadly consistent with the preceding year, allocating all expenditure solely by sales turnover was unsupported. The claimed deduction consequently remained sustainable.

Statutory limitation under Sections 153A and 153C permitted an extended ten-assessment-year period where alleged escaped income exceeded the prescribed threshold. The period was calculated backwards from the assessment year in which the satisfaction note was recorded. With the satisfaction note recorded in assessment year 2022-23, the extended period reached only up to assessment year 2013-14. Assessment year 2010-11 therefore fell outside the permissible period, rendering the assessment order time-barred.

Revisionary jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to the Revenue. Where reassessment followed notices, explanations and supporting material furnished by the assessee, revision cannot rest solely on the same portal information already examined. A perceived need for further inquiry is insufficient unless the revisional authority identifies a lack of inquiry, a specific error or discrepancy in the assessee's material, and resulting prejudice to the Revenue. In these circumstances, the prerequisites for revision were not met and the revisionary order was invalid.

Income-tax processing, rectification and revision must consider all material particulars disclosed in the return and provide reasons. A computation addressing only receipts and an exemption claim while disregarding reported expenditure reflects non-application of mind. A rejection of rectification without reasons is similarly defective. The intimation and the rejections of rectification and revision were set aside, with fresh consideration of the rectification application required in light of the return and relevant observations.

Reassessment founded on an audit objection alleging a health and education cess deduction requires verification that the deduction was actually claimed; an unverified factual premise demonstrates non-application of mind and cannot support reopening. Interest on borrowings invested in a subsidiary remains allowable where the investment is commercially expedient and connected with business purpose. Business purpose is not limited to the taxpayer's immediate profit-making activity, and the Revenue cannot replace a prudent businessperson's commercial judgment. Consequently, neither objection supplies a sustainable basis for reassessment.

Section 260A confines High Court review to substantial questions of law and bars reassessment of evidence or replacement of a plausible factual view. A Tribunal's factual finding may be disturbed only if perverse, unsupported by evidence, materially incomplete, or based on inadmissible material. For the Section 68 addition, investment disclosures, transaction records, bank evidence, purchaser confirmations, financial statements, tax returns and notice responses supported the sale proceeds. Human probabilities and surrounding circumstances could not convert suspicion or general allegations into proof. No substantial question of law arose, so deletion of the addition remained affirmed.

Section 69A addition for alleged unexplained money cannot rest on uncorroborated search or survey material, a promptly retracted statement, or suspicion, conjecture and surmise. Although technical evidence rules do not strictly apply in income-tax proceedings, relevant independent material is required before drawing an adverse inference, consistent with natural justice. Because the brokers' material related to an earlier period and no broker statements or other evidence established investment or interest income, the deletion was sustained and no substantial question of law arose.

Reassessment under section 147 read with faceless assessment provisions raised the issue whether the Assessing Officer could proceed with assessment after issuing a notice under section 143(2). The special leave petition was dismissed without interference with the High Court's order, leaving the challenged reassessment ruling and the Assessing Officer's jurisdiction to proceed undisturbed.

Proceedings under section 153A were challenged because the approval under section 153D was allegedly vitiated by total non-application of mind. The Supreme Court declined to interfere with the High Court order and dismissed the Special Leave Petition, leaving that order undisturbed.

Jurisdiction over scrutiny notices under section 143(2) arises where one tax officer issued the notice and another completed the assessment under section 143(3). The central issue is whether an assessee may challenge either officer's authority despite provisions that cure certain procedural defects and limit objections to notice defects. Sections 292B and 292BB are relevant to the validity of the notice and the resulting assessment. Questions concerning the officers' respective jurisdiction and the operation of these defect-curing provisions remain for consideration in appellate tax proceedings.

Limitation for completing a fresh assessment after remand arose under sections 153(3) and 153(4), including whether failure to complete the assessment within the prescribed period results in deemed acceptance of the return. The Supreme Court declined to interfere with the High Court's judgment and dismissed the special leave petition, leaving that judgment undisturbed. Pending applications were also disposed of.

For GST appeals, the prescribed statutory pre-deposit must be paid, but an appeal is treated as filed in law only when the final acknowledgement is issued under the appellate rules. Where the Registry identifies non-payment as a defect, payment made within the permitted rectification period and before final acknowledgement satisfies the pre-deposit requirement. Initial non-payment therefore does not invalidate the appeal when the defect is cured before the final acknowledgement is issued.

Documents already relied upon in the show cause notice were treated as not constituting additional evidence when sought to be placed on record in appeal. The related proposed ground was regarded as corroborative of those documents rather than a new ground. The request to place the documents on record and amend the appeal was allowed. Further authorities could be cited, and reliance on authorities previously cited could be withdrawn without objection.

The First Appellate Authority's power to condone delay under Section 107 is confined to the statutory outer limit; constitutional orders issued on particular facts cannot enlarge that jurisdiction. Condonation beyond that limit is ultra vires. Restoration of cancelled GST registrations by the Department, followed by taxpayers resuming business and complying with obligations, leaves no effective relief in a subsequent departmental challenge seeking annulment. Implementing restoration and then challenging it engages the bar against approbating and reprobating. Revocation under Section 30 and an appeal against cancellation under Section 107 are independent remedies, so inability to apply for revocation within the Rule 23 period does not bar the statutory appeal. Restored registrations therefore remain undisturbed.

Section 107 confines the First Appellate Authority's power to condone delay to the prescribed appeal period plus the statutorily permitted further period; equitable considerations and High Court powers under Article 226 cannot enlarge that jurisdiction. Delay condoned beyond the outer limit is therefore beyond jurisdiction. Implementation of registration-restoration orders may nevertheless make a departmental challenge ineffective where restoration has altered parties' positions, enabled continuing compliance, and created genuine intervening transactions. Revocation under Rule 23 and appeal against cancellation operate as alternative remedies, so inability or failure to seek revocation does not bar a statutory appeal.

Section 129 of the CGST Act does not sustain a confiscatory penalty for return transit of fully duty-paid, accounted imported goods to a customs warehouse after an aborted delivery where no intent to evade tax is established. Although section 68 and rule 138 require movement documentation, absence of a fresh e-way bill, without discrepancies in quantity or description, diversion, unrecorded sale, or revenue loss, is a bona fide procedural lapse. Such a default attracts only the general penalty under section 125. Jurisdictional precedent treating bona fide transit-documentation failures as outside section 129 applies, while authorities involving deliberate commercial non-compliance are distinguishable. Consequential refund and release relief follows.

Section 112(3) confines a departmental challenge to points authorised by the Commissioner, preventing an authorised officer from raising an omitted objection to IGST credit utilisation. Priority utilisation of IGST credit under the statutory framework does not create unjust enrichment where equivalent unutilised CGST and SGST credit remains available to debit the refund amount. Judicial invalidation of the ocean-freight IGST reverse-charge levy operates retrospectively unless expressly limited, rendering the levy void from inception. Taxpayers who were not parties to the invalidating litigation may rely on that declaration to seek refund, subject to finality exceptions, with statutory interest for delayed payment.

Input tax credit claims in pending FY 2017-18 proceedings require verification of invoices, receipt of supplies, payment records, supplier-side tax compliance, books and reconciliation material. A numerical mismatch between GSTR-3B and GSTR-2A cannot by itself justify denial of credit under the prescribed verification procedure. Chartered Accountant certificates may serve as corroborative evidence where correlated with contemporaneous records. First appellate rejection for non-appearance, without determining credit eligibility and tax liability on merits, fails to provide a reasoned adjudication consistent with natural justice. Fresh determination should consider the certificate, invoices, ledger records and reconciliation material.