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.

Combined trade estimates for April-September 2026-27 show exports of US$ 476.20 billion and imports of US$ 551.13 billion, resulting in a trade deficit of US$ 74.93 billion. Merchandise exports rose to US$ 259.89 billion, while merchandise imports reached US$ 437.53 billion. Estimated services exports were US$ 216.31 billion and services imports were US$ 113.60 billion, producing a services trade surplus of US$ 102.71 billion. September services figures are estimates, and specified earlier-period data were revised using quarterly balance-of-payments data.

Where premises form part of the corporate debtor's assets, Sections 18 and 25 of the Insolvency and Bankruptcy Code, 2016 require the resolution professional to take custody, control, preservation and protection measures. An occupant resisting recovery must prove a subsisting tenancy, leasehold interest or enforceable licence through reliable evidence of the parties' intended relationship and its essential terms. Permission to stock goods or conduct limited business activity, prolonged occupation, and business or utility records do not independently create rights in the premises. Section 60(5)(c) supports insolvency jurisdiction over asset-recovery measures connected with the insolvency estate.

Land consistently recorded as a fixed asset since 2007 and held for more than three years retains its character as a capital asset rather than stock-in-trade, notwithstanding separate land-trading activity. Taxpayers may maintain distinct investment and trading portfolios for immovable properties; classification of other land as trading assets does not, by itself, convert investment land into trading stock or an adventure in the nature of trade. Transfer of the Nikol land therefore gives rise to long-term capital gains, with deduction under section 54F available.

Supplies of short-term accommodation, conferencing and banqueting to SEZ developers or SEZ units are inter-State supplies because the specific SEZ supply rule prevails over the general place-of-supply rule. Zero-rated treatment and refund for supplies to SEZs require use for authorised operations and endorsement by the specified Zone officer. Suppliers of goods require confirmation of full admission into the SEZ, while suppliers of services require endorsed evidence of receipt. Fabric processors supplying job work services may obtain inverted-duty-structure refunds of unutilised input tax credit.

Tax determination for financial year 2024-25 onwards is governed by section 74A for unpaid or short-paid tax, erroneous refunds, and wrongly availed or utilised input tax credit. Notices must generally be issued within forty-two months, and orders within twelve months, subject to a limited extension. Penalties differ between ordinary defaults and fraud, wilful misstatement, or suppression. In ordinary cases, payment of tax and interest before notice prevents notice and penalty, while payment within sixty days after notice avoids penalty. Fraud cases permit conclusion on payment of tax, interest, and specified penalties at pre-notice, post-notice, or post-order stages.

Reasonable cause for delayed filing may be established where an authorised representative fails to communicate a first appellate dismissal, the assessee acts promptly after receiving a demand notice, and pandemic-related lockdowns explain the intervening period. An ex parte dismissal for non-prosecution, without examination of additions or disallowances on merits, requires restoration for merits-based adjudication when non-appearance is satisfactorily explained. Adequate opportunity of hearing must be afforded before determining the first appellate challenge in accordance with law.

GST portal service is a statutory method under Section 169, but its use in an ex parte demand proceeding depends on effective accessibility and a meaningful opportunity to reply and be heard. Rule 142 requires electronic DRC-01 and DRC-07 summaries to operate alongside the underlying show-cause notice and reasoned order. Portal placement, complete communication, e-mail transmission, technical reliability and proof of actual access may determine whether service is effective, whether waiver applies, and whether appellate limitation begins.