Rectification of an error apparent on the face of the record may be made without an opportunity of hearing where the correction does not alter the advance ruling, increase tax liability, or reduce admissible input tax credit. An inadvertent typographical reference to B30 in a specified expression was deleted because the error was apparent from the record. The correction left all other findings, discussions, and the substantive ruling unchanged.

Current-repairs treatment applied to expenditure replacing dies and moulds, allowing the claim. Capital scientific-research expenditure and weighted research-and-development expenditure on work-in-progress qualified for the stated deductions. Notional profits from captive power generation qualified for the relevant deduction, and foreign-agent commission for overseas business promotion was deductible. UPS and voltage stabilisers used with computers qualified as computer peripherals for depreciation at 60%. Depreciation on a temporary parking shed was limited to 10%, with the Revenue's position restored.

Reassessment of short-term capital loss attributed to a mutual fund's alleged accounting manipulation is impermissible when the allegations are identical to those previously considered in a final, applicable determination. Where scrutiny assessment specifically examined the loss and the taxpayer's explanation, reopening requires fresh tangible material beyond the material already assessed; otherwise it constitutes a change of opinion. On both grounds, the reassessment order and consequential notice were quashed.

Urban Improvement Trust income does not qualify for local-authority exemption, and exemptions requiring Central Government notification apply only from the notification's effective date. Constitutional immunity applies only to income legally belonging to the State; income of a separate statutory corporation remains its own despite its public functions. Charitable registration benefits earlier years only where assessment proceedings were pending when registration was granted; an information notice alone is insufficient. Reassessment may rest on non-filing of returns and taxable surplus. Taxability of statutory collections and refundable advances requires examination of overriding title, liabilities, accounting treatment, and remittance or refund evidence; omission to specify an income head does not itself invalidate assessment.

Royalty liability on rejection or waste-dump sales from preceding financial years becomes deductible business expenditure when no earlier demand existed and the liability is first quantified and crystallised in the relevant year. This treatment applies notwithstanding mercantile accounting, because the enforceable liability arose only upon the later demand. Interest for delayed payment of such royalty is also deductible where it is compensatory rather than penal, follows the royalty demand, and is incurred wholly and exclusively to maintain continuity of mining operations. The royalty and compensatory-interest disallowances were deleted.

Penalty for failure to deduct tax at source is not automatic where the deductor establishes reasonable cause. The interaction of section 271C and section 273B excludes penalty if a bona fide belief concerning commission payments, coupled with accounts-department changes causing an inadvertent TDS oversight, explains the default. On those grounds, the penalty for non-deduction was deleted, while other grounds did not require determination.

The proviso to section 87A entitles an assessee to a tax rebate where total income chargeable under section 115BAC(1A) does not exceed Rs. 7,00,000. As the income satisfied that statutory threshold, restricting the claimed rebate was unsustainable. The rebate was allowed and the Revenue's appeal was dismissed.

Limited remand proceedings cannot reopen a stamp-duty valuation issue that earlier appellate directions did not keep open; the request for a valuation-officer reference therefore failed. Capital-gains exemption for transfer of agricultural land requires reliable proof that the land was used for agriculture by the assessee or a parent during the prescribed period; sale-deed description alone was insufficient, so the exemption was denied. Unsupported opening cash and banking entries without a direct nexus did not establish the source or genuineness of the investment. Likewise, creditor identity and bank receipt alone did not prove a refundable property advance where the agreement, cancellation and cash repayment were undocumented. The challenged additions were sustained.

CBDT Instruction No. 1916 prescribes guidelines for seizure of jewellery during search; it does not grant an unconditional exemption from assessment. The source, nature and ownership of jewellery must be established on the facts. Joint residence does not by itself create a common ownership pool or permit adjustment of other family members' permissible limits against jewellery separately identified in one person's bedroom, particularly where that benefit has been considered in other assessments. On these facts, the addition for unexplained gold jewellery was sustained.

Compliance with an operative interim judicial direction requiring a bank not to treat foreign-leg Leave Fare Concession reimbursements as employee income for tax deduction purposes precluded default treatment for the relevant payments. A later determination that such reimbursements were substantively taxable for another assessment year could not retrospectively transform compliance with that binding direction into a failure to deduct tax under section 201(1). Consequently, interest under section 201(1A), which depended on the alleged default, was unsustainable.

Search-derived material for an assessment year covered by Explanation 2 to section 148 requires use of the special reassessment mechanism under sections 147 and 148. A pending scrutiny proceeding initiated by notice under section 143(2) cannot be completed under section 143(3) where that mechanism applies, because the special regime overrides regular scrutiny. Prior approval under section 148B is mandatory; administrative or supervisory approval under a CBDT instruction does not satisfy that requirement. The assessment for AY 2022-23 was quashed on both grounds, without adjudication of additions on merits.

Restoration of the statutory customs appeal was warranted because the appellants had no opportunity to contest the exemption claim on merits before an appellate forum. Dismissal of the writ petition and restoration application on technical grounds relating to liberty to revive the appeal did not justify denial of a first appellate hearing. The right of appeal was treated as a valuable remedy requiring at least one forum to address grievances on merits. The impugned orders were set aside and the customs appeal restored to its original number for disposal on merits within the directed time.

Admission of a creditor's claim by a Resolution Professional is an administrative or clerical act of collating claims and does not amount to a conscious, unequivocal acknowledgment of a subsisting debt. An acknowledgment can extend limitation only when made before expiry of the prescribed limitation period. Where limitation had already expired before the insolvency application against a personal guarantor was filed, the Resolution Professional's admission of the claim could not revive or extend the period. The financial creditor's application under Section 95 was therefore barred by limitation, and the admission order was set aside with dismissal of the company petition.

Potential accused affected by a judicial direction to register an FIR, investigate, and file a final report have locus to seek leave to appeal even if they were not impleaded in the original writ proceedings. The Supreme Court treated the finding that the material disclosed cognizable offences as capable of prejudicing a later independent challenge to the FIR. It also recognised that directions extending to investigation and filing of a final report may require consideration of statutory requirements under the applicable special law. Refusal of leave was set aside, the appeals were restored before the Division Bench, and interim relief could be sought in accordance with law. The BNSS discussion did not address merits.

Corporate guarantees furnished to wholly owned foreign subsidiaries are international transactions under the Explanation to Section 92B and require arm's-length benchmarking; a 0.50% guarantee commission applies rather than 1%. Sales commission paid to a United States associated enterprise for marketing and support services did not constitute fees for included services under Article 12(4)(b) of the India-US tax treaty and was not taxable in India; therefore, no withholding obligation or consequential disallowance arose. The SEZ-unit deduction claim requires reconsideration using Form 56F, a bifurcated profit and loss statement, and the computation of eligible profits, without a merits determination of eligibility or quantum.

Reassessment procedure requires the Assessing Officer to decide an assessee's objections to reopening through a speaking order before commencing scrutiny assessment. A scrutiny notice initiates scrutiny and cannot be issued before those objections are disposed of. Premature initiation of scrutiny is a jurisdictional defect, rather than a procedural irregularity, rendering the reassessment proceedings and consequential assessment order invalid. The reassessment and consequential assessment order were quashed, making challenges to the assessment's merits academic.

Reasonable limitation applies to TCS-default orders where section 206C contained no express limitation period. An additional limitation ground may be considered as a pure question of law when it concerns jurisdiction, all material dates are on record, no further factual inquiry is needed, and the ground was raised before but left undecided by the first appellate authority. Applying an analogous limitation principle for tax-deduction defaults, four years from the end of the relevant financial year was treated as reasonable. A later statutory time limit did not govern earlier proceedings. Proceedings initiated after that period, including consequential interest, were treated as time-barred.

Business-loss set-off against capital gains and other income required fresh verification where return processing adopted deemed income not reflected in the taxpayer's computation. The computation was not intelligible despite undisputed income and loss figures, and rejection of the set-off claim had not considered cited judicial precedents. Recalculation must examine applicable deemed-income provisions and subsequent-year records to prevent double deduction. The appellate order was set aside and remanded to the Jurisdictional Assessing Officer for fresh determination of total income and tax liability after hearing the taxpayer.

Cash-payment disallowance under section 40A(3) does not extend to overwhelmingly genuine business payments solely because they were made in cash. In the unorganised liquor trade, the cash component of sales receipts and the nature of supplier payments may explain cash expenditure. Although the claim that individual payments remained within the applicable daily statutory limit was rejected based on the assessment record, the supplier payments were treated as duly explained and genuine. The cash-expenditure disallowance was consequently deleted.

Finality of an unchallenged remand order prevented the exporter from reopening findings that its declared FOB value was doubtful, Revenue had met its burden, and the value required re-determination. The Tribunal treated those findings as conclusive because neither side had challenged the earlier order, and held the later challenge to re-determination not maintainable. Examination was therefore limited to compliance with the remand directions. As the Commissioner considered values for the different exported watches and re-determined FOB value under the Valuation Rules, 1988, the Tribunal upheld the re-determination and dismissed the appeal.