Under the post-1 July 2012 service-based taxation framework, service tax paid under differing service heads or financial years must be adjusted against aggregate liability when determining short payment. Accounting heads primarily serve revenue-accounting and exemption purposes and do not alter the fact of tax payment. Where statutory returns show aggregate payments exceeding recalculated liability for the disputed period, credit cannot be denied merely because payments relate to a different taxable service or year. Consequently, no unpaid service tax, interest, or penalty remains.

Section 45 of the Prevention of Money-laundering Act imposes twin conditions for bail, but their application must remain consistent with Article 21 protections of personal liberty and speedy trial. Where charges remain unframed and completion of extensive money-laundering and predicate-offence trials is not reasonably foreseeable, prolonged pre-trial detention cannot become punitive or indefinite. Compliance with bail conditions in the predicate case, the availability of stringent safeguards, and parity with similarly placed co-accused support satisfaction of the statutory conditions. Parity does not require an applicant to undergo the same duration of custody as co-accused before conditional bail may be granted.

A fresh exemption claim omitted from an original return and not examined during processing cannot be introduced through rectification. Rectification is limited to correcting a mistake apparent from the record, not advancing a new claim requiring examination. Consequently, the exemption claim remained outside the scope of rectification under the Income-tax Act.

Unsecured-loan credits require complete evidence satisfying the cash-credit conditions under Section 68; partial material warrants fresh consideration after the taxpayer has an opportunity to substantiate the claim. A personal loan credited to the capital account likewise requires supporting evidence and is subject to reconsideration where none was furnished. The estimated disallowance of discount and godown expenses was treated as excessive and confined to 5%.

Fresh adjudication was required for additions concerning unaccounted expenditure, sundry creditors, and a differential amount. Explanations based on audited books, progressive business results, subsequent repayment of rent provisions, and the stated marginal difference warranted consideration. The assessee was required to substantiate those explanations before the appellate authority, which would reconsider the additions on that basis.

Section 68 cash-credit additions for unsecured loans cannot be sustained where unrebutted lender confirmations, income-tax returns, bank statements, computations and ledger accounts establish creditor identity, creditworthiness and transaction genuineness. Interest payments after tax deduction at source further support the loan transactions. Additions for alleged bogus purchases are unsupported where purchase bills, VAT/GST returns and supplier account statements corroborate the purchases, figures match the supplier's books, and no discrepancies in statutory returns or other adverse material are established. On these evidentiary bases, both additions were deleted.

Representative capacity to pursue a deceased assessee's tax appeal requires proof that the claimant is a legal representative under the Income-tax Act and the Code of Civil Procedure. Where no material establishes management of, or intermeddling with, the estate, and no proceedings have been taken against the claimant for the deceased's tax liability, the claimant lacks locus standi in a representative capacity. Failure to establish that status prevents maintenance of the appeal.

Transfer-pricing analysis must be confined to actual international transactions with associated enterprises, rather than total turnover, and transaction values must be verified with the taxpayer given an opportunity to reconcile discrepancies. Delayed foreign-currency receivables are benchmarked after a 60-day credit period using six-month LIBOR plus 200 basis points unless circumstances justify departure. Prior-period travel and legal expenses require verification of liability crystallisation, prior allowance and exclusive business nexus. Revised computations correcting taxable income require merits consideration despite absence of a revised return, subject to verification of the provision's accounting and tax basis.

Cash-credit additions require the taxpayer to establish lender identity, creditworthiness and transaction genuineness. Confirmations, bank statements, financial records and repayment evidence can discharge that burden. An untested retracted third-party statement, without cross-examination or cogent rebuttal material, cannot by itself displace such documentary proof consistently with natural justice. Where loan transactions stand established, an estimated unexplained-expenditure addition premised on accommodation entries lacks an independent basis and is unsustainable.

Section 68 requires proof of the contributor's identity, transaction genuineness and creditworthiness. Partner capital contributions represent ownership interests rather than borrowings, and the additional source-of-source requirement applicable to specified share-capital credits of closely held companies does not extend to partnership firms. Where identified partners confirm and own their contributions, supported by affidavits, financial records and banking-channel remittances, doubts about the ultimate source in their foreign bank accounts are relevant to their individual assessments, not the firm's income. Reliance on an undisclosed remand report without an opportunity to rebut it conflicts with natural justice; further verification is unnecessary absent material that the firm's undisclosed income was routed through partners.

Reassessment initiated by a notice under section 148A(b) within three years from the end of the relevant assessment year falls under section 149(1)(a), for which PCIT approval under section 151 is valid. Search-derived information from another person's case does not by itself displace the jurisdictional Assessing Officer. A political-donation deduction under section 80GGC is unavailable where unrebutted search statements and seized records connect the recipient political party with accommodation-entry operations; payment through banking channels and donation receipts alone do not prove the transaction's genuineness.

Section 37(1) does not support an addition for alleged bogus expenditure unless the relevant amount was claimed as business expenditure. Where the amount was not claimed as an expense, no disallowance or matching addition arises. Taxing the same receipts again, after they have been offered to tax and assessed in recipients' hands, would create double taxation. On those stated facts, the addition for alleged bogus expenditure was unsustainable and remained deleted.

Section 151A permits a faceless scheme for proceedings under Section 148A, but the notified e-Assessment Scheme and Section 144B require automated allocation only for assessment, reassessment or recomputation under Section 147 and issuance of a Section 148 notice. Until a notified scheme extends to the preliminary Section 148A stage, the jurisdictional Assessing Officer may issue the Section 148A(b) notice and pass the Section 148A(d) order; the ensuing assessment must follow the faceless mechanism. For AY 2017-18, the ten-year limitation under Section 149(1)(b) applies where recorded escaped income exceeds the statutory threshold, and the preserved earlier-law limitation does not bar notice on facts involving cash transactions and immovable-property sale.

Long-term capital gains exemption on share sales and deletion of an unexplained-credit addition were sustained where purchase and sale transactions were supported by documentary records, banking channels, demat accounts, recognised stock-exchange trades and long-term holding. Suspicion, presumptions and an uncorroborated preponderance-of-probabilities assertion could not displace the established genuineness of the transactions without evidence linking the taxpayer to entry operators, cash payments or scrip manipulation. No substantial question of law arose from the findings.

Reassessment was challenged on grounds of change of opinion, absence of fresh tangible material, and impermissible review by the Assessing Officer. Following the subsequent assessment order and dismissal of the first appellate challenge, the writ petition was dismissed because a further appeal was pending before the Tribunal. All grounds available in law, including the challenge to reopening, remained open for consideration in the pending appellate proceedings.

Pre-1 April 2021 reassessment notices issued within four years, including under the applicable COVID-19 limitation extension, required sanction from the Joint Commissioner under section 151(2). Sanction by the Principal Commissioner, who was not the specified authority, created a jurisdictional defect because statutory approval requirements required strict compliance. The reassessment notice was therefore invalid, and the objection-disposal order, assessment order, demand notice, penalty-initiation notice and consequential proceedings were quashed.

GST registration cancellation based on a show-cause notice that cites Section 29(2)(e) without factual particulars, while relying on unavailable supporting enclosures, requires a fresh opportunity to respond. Following supply of the enclosures to counsel, the cancellation order was set aside. The taxpayer may file a reply within three weeks, and the competent authority must consider it according to law, grant a personal hearing, and communicate a written decision. The dispute over prior service of the enclosures remains unresolved.

Renewable Energy Certificates, Priority Sector Lending Certificates and similar documents are classifiable under heading 4907 and attract GST at 12%. The residual rate entry applies only to goods not covered under another specified schedule entry and cannot be used where a specific classification applies. The earlier residual-entry treatment of PSLCs is modified accordingly. Duty credit scrips classifiable under heading 4907 remain subject to Nil GST under the specified exemption entry.

Prior GST clarifications concerning the supply of Information Technology enabled Services (ITeS) are withdrawn ab initio following apprehensions about their implications. Statutory direction-making power is exercised to secure uniform implementation across field formations, discontinuing the earlier clarificatory framework for GST treatment of ITeS supplies.

GST treatment of food or drink supplied through a mess or canteen in an educational institution, including a college hostel mess, falls within the catering-services rate framework. Food and drink supplied by Indian Railways, its catering company, or their licensees in trains or platform-based static units is subject to GST at 5 per cent without input tax credit, under a separate rate entry aligned with the corresponding central position.