Stamp duty on a sale certificate issued following an insolvency liquidation e-auction is determined by the auction value where the process establishes the assets' true market value. The expression "Civil Court" in Article 16 extends to an auction conducted by a liquidator appointed under the insolvency framework, following independent valuation, reserve-price fixation, public e-auction and reporting to the Tribunal. An ASR-based valuation cannot displace the realised auction value without a valid basis to find intentional suppression or reduction of value to evade stamp duty. Registration is consequently to proceed on the auction value recorded in the liquidator's sale certificate.

Judicial review of the administrative write-down must assess legality against the facts and law existing when it occurred; subsequent financial developments cannot alter that inquiry. Omission from the final Reconstruction Scheme of an express AT-1 bond write-down provision meant that a general savings clause could not imply authority for the Administrator to alter the bonds. The Master Circular required conversion or write-down before the Scheme took effect, and the power at the point of non-viability lay with RBI rather than an Administrator exercising board powers. The post-scheme write-down was therefore ultra vires, was set aside, and coupon payments remained governed by the Information Memoranda.

A domestic company may claim an inter-corporate dividend deduction for qualifying dividends received from domestic or foreign companies or business trusts, limited to dividends distributed within the prescribed period. Under the 2025 Act, distribution must be made at least one month before the return-filing due date. The corrected safe distribution date identified for an audit-case return due on 21 November 2026 is 20 October 2026. The same distributed dividend cannot generate a deduction in another tax or previous year.

Retrospective cancellation of a supplier's GST registration warrants inquiry but does not alone prove invalid invoices, non-receipt of goods, non-payment of tax, or ITC ineligibility. Invoice-related eligibility must be assessed on the date of issuance and under the statutory conditions applicable to the relevant tax period. A show-cause notice must identify the actual ground for denying credit; cancellation alone cannot later be supplemented by unalleged claims of fictitious supply, non-receipt, or supplier tax default. Administrative scrutiny flags may prompt verification but cannot create a disqualification beyond statutory ITC conditions.

Rectification under section 154 requires an Assessing Officer to identify a self-evident mistake from the record through independent application of mind. The record includes materials and documents available when the order proposed for rectification was passed. Errors requiring prolonged reasoning, complicated arguments, or resolution of two reasonably possible views do not qualify. Accepted revenue audit objections must be addressed through the appropriate statutory mechanism, including revision or reassessment where applicable, with sufficient reasons for invoking section 154.

Service of a Section 8 demand notice upon the Key Managerial Personnel of a corporate debtor at its registered office, in their official capacity, may constitute deemed service on the corporate debtor. The statutory purpose is satisfied where the corporate debtor receives an effective opportunity to pay the operational debt or raise a dispute. A procedural irregularity in addressing the notice should not defeat substantive rights where the corporate debtor suffers no substantial prejudice.

GST treatment of road-restoration charges turns on the payment's legal character rather than its label. Charges paid under a prior arrangement granting excavation permission and requiring identified restoration may be consideration for a taxable service, unlike genuine compensation for damage or breach without reciprocal obligations. Government involvement and a connection with public roads do not alone establish non-supply or exemption. Reverse charge applies only after taxable supply and notification coverage are established, and any refund claim must show that tax was not legally payable.

GST appellate pre-deposit is calculated on the tax actually disputed before the Tribunal. An eligible earlier payment, verified, linked to the relevant demand and available for adjustment, may satisfy the aggregate first-appeal and Tribunal components without a fresh challan when it covers the recalculated requirement. A remanded component remains separate rather than being treated as deleted; deposits must be specifically allocated and cannot be reused. Recognition of an existing deposit remains subject to admitted-tax payment, applicable limits, demand mapping, filing fees and other appeal conditions.

GST refund claims subject to a deficiency memo in FORM GST RFD-03 must, pending portal functionality, be rectified and resubmitted under the original ARN. Re-credit of input tax credit to the electronic credit ledger through FORM GST RFD-01B is not required, and jurisdictional tax authorities must accept the rectified claim under that ARN. Separate treatment is contemplated where re-credit has already occurred.

Section 8 of the Court Fees Act, 1870 requires ad valorem court fee on land-acquisition compensation appeals, calculated on the difference between the amount awarded and the amount claimed by the appellant. Additional compensation, solatium and statutory interest are mandatory, inseparable components of the composite compensation award. As the Reference Court's award is a deemed decree, an appeal seeking reduction or exclusion of any quantified statutory component seeks modification of that decree. Section 8 contains no exemption for appeals confined to statutory additions; fixed court fee is therefore insufficient.

Redemption of mutual fund units acquired through surplus-fund investments for liquidity management is distinct from trading in goods or providing an exempted service. Accordingly, the common-input-service reversal or payment mechanism under Rule 6(3)(i) of the Cenvat Credit Rules, 2004 does not apply. Notice-pay compensation recovered from employees leaving without completing their stipulated notice period compensates premature departure; it is not consideration for agreeing to tolerate an act or situation and is not a declared service under Section 66E(e) of the Finance Act, 1994. No service-tax liability arises from either activity.

Mechanical, combined and non-speaking statutory approval without demonstrated application of mind fails the mandatory safeguard for search assessments, rendering the affected assessments void. Depreciation on a non-compete fee remains allowable within a block of assets when accepted in an earlier year and no changed circumstances exist. Rental receipts from property first let during the relevant year are taxable as Income from House Property, with the applicable statutory deduction. Exempt-income expenditure cannot be disallowed through the prescribed mechanism unless dissatisfaction with the taxpayer's accounts is recorded. An additional legal ground challenging assessment validity is admissible where all necessary facts already appear on record.

The Finance Act, 2022 amendment to section 14A operates prospectively and does not govern assessment years 2017-18 and 2020-21. Rule 8D computation requires the Assessing Officer to record, after examining the accounts, dissatisfaction with the correctness of the taxpayer's own disallowance; general observations on investments, mixed funds, or administrative expenses do not meet that condition. A notional section 14A disallowance cannot be added to book profit under section 115JB merely through clause (f) of Explanation 1, which is confined to specified amounts debited to the profit and loss account. The additional disallowance and corresponding book-profit adjustment are unsustainable.

Cash-deposit addition in an income-tax assessment required consideration of the taxpayer's explanation that deposits arose from prior withdrawals and past savings. The explanation was partially substantiated, and an allowance for past savings was considered warranted. The addition was consequently restricted to the supported extent, while the remaining balance was deleted in full.

Section 69B unexplained-investment additions cannot rest solely on an estimated construction valuation where the recorded investment appears in books of account that have not been rejected and no material establishes actual excess cash investment. In those circumstances, reliance on a valuation reference for making the addition is impermissible. Self-supervision allowance in construction valuation must be computed on the gross valuation rather than only on the differential amount. These principles limit valuation-based additions to situations supported by evidence beyond estimation.

Penalty under Section 271C was not sustainable where a materially incorrect loss disclosure could plausibly be attributed to clerical error. The substantial difference between the disclosed and actual losses supported that possibility, rather than establishing a basis for penalty. The penalty was therefore deleted in favour of the assessee on the stated facts.

Statutorily mandated contributions earmarked for accumulation, with only the interest available for welfare objects, have the capital character required for corpus treatment. Restrictions preventing use of the principal for the trust's objects provide the specific direction necessary to treat the receipts as corpus. Such contributions are not assessable as income. Further, Section 12(1) covers voluntary contributions; if the contributions are non-voluntary, they independently fall outside that provision's scope. The resulting addition is deleted.

Income surrendered during a survey for unrecorded loans to debtors and excess cash, when entered in the regular books before the return is filed and offered to tax, remains business income where it arises from the taxpayer's grain, oilseed and pulses trading activities. In the absence of material showing an independent source of income, the unexplained investment and money provisions do not apply. Consequently, the special tax rate for such unexplained income is inapplicable, and the disclosed additional income is taxable at normal business-income rates.

Alleged bogus purchases and unrecorded sales receipts require fresh verification where the taxpayer seeks to substantiate reconciliations and supporting material. The admitted bogus input-tax-credit claim does not remove the need to examine explanations concerning purchases, sales receipts, and documents placed on record. Fresh consideration by the Assessing Officer is required after providing a reasonable opportunity of hearing, so that the reconciliation and supporting evidence can be properly evaluated.

Higher-rate taxation under Section 115BBE requires establishing that income voluntarily declared in a search-assessment return is unexplained or undisclosed income. A declaration alone, without incriminating material or a separate addition, does not satisfy that requirement where the income is stated to arise from regular business. In those circumstances, the declared income is assessable at the regular tax rate rather than the higher rate under Section 115BBE.