Reassessment notices issued beyond three years from the end of the relevant assessment year may rely on the extended limitation only where escaped income, represented by an asset, is at least Rs. 50 lakh. Where the alleged escaped income fell below that threshold after excluding a non-taxable agricultural-land transaction, the extended period under section 149(1)(b) was unavailable. The notice under section 148 and consequential assessment were therefore barred by limitation.

Rebate under section 87A is available to an assessee chargeable under section 115BAC(1A) where total income, including short-term capital gains taxable at special rates, does not exceed Rs. 7,00,000. The proviso focuses on total income and does not exclude income taxable at special rates from determining eligibility. Restricting the rebate despite total income remaining within the statutory threshold was unsustainable, and the full prescribed rebate applied.

Section 87A rebate applies to short-term capital gains taxable under Section 111A where total income, including those gains, remains below the prescribed threshold and the rebate is within the applicable limit. The restriction expressly applicable to long-term capital gains under Section 112A(6) does not extend to short-term capital gains under Section 111A. Consequently, rebate may be claimed against such short-term capital gains, and a disallowance on that basis is not sustainable.

Pure legal challenges to a reassessment notice may be admitted where they require no further factual inquiry and affect the root of reassessment. However, grounds not adjudicated by the first appellate authority do not arise from its order and cannot be determined at the Tribunal stage. The first-appellate order was set aside, and the reassessment challenge and remaining grounds were remitted to the Commissioner (Appeals) for adjudication. No determination was made on reassessment validity or the addition.

Reasonable cause under section 273B precludes penalty for failure to deduct tax at source under section 271C when the taxpayer proves that the default was not deliberate. Relevant factors include consistent tax deduction on other payments, a bona fide understanding of the tax treatment of commission payments, and disruption of compliance functions following changes in key accounts personnel. These circumstances support the conclusion that non-deduction was inadvertent and lacked an intention to evade tax, so penalty under section 271C is not sustainable.

Under the mercantile system, royalty liability for rejection or waste dumps sold in earlier periods crystallises when it is first asserted and quantified, provided no earlier demand existed and the taxpayer held a bona fide belief that royalty was not payable. Its deduction is therefore not denied merely as a prior-period item; the matching concept does not displace crystallisation of liability. Interest on delayed payment of such royalty is deductible as business expenditure under section 37(1) where it is compensatory rather than penal, arises from business expediency, and involves no breach or infraction of law. Royalty and consequential compensatory interest are deductible in the year the liability crystallises.

Statutory authorities with separate corporate personality, assets, funds and liabilities cannot treat their income as State income under Article 289(1) merely because they perform public functions or remain subject to State control. Urban improvement trusts are outside the local-authority exemption, while exemptions for specified bodies depend on Central Government notification; notification under the newer provision applies only from assessment year 2026-27. Retrospective trust-registration relief requires assessment proceedings pending on the registration date; preliminary information inquiries do not qualify. Reassessment may proceed where unfiled returns and taxable surplus constitute deemed income escapement, subject to procedural requirements. Taxable surplus need not fail solely because no income head is specified, but receipt-level questions of overriding title, liabilities, remittances and refunds require factual verification in computing taxable income.

Penalty for misreporting requires delayed employees' PF/ESI contributions to fall within a specified statutory category of misreporting. Mere disallowance of a claim, without evidence that the conduct meets one of those categories, does not establish misreporting. Accordingly, disallowance of employees' PF/ESI contributions solely for delayed payment cannot by itself support a misreporting penalty, which is unsustainable absent the prescribed statutory basis.

Compensation received by BSNL employees under the 2019 Voluntary Retirement Scheme is exempt under Section 10(10B) of the Income-tax Act. Earlier coordinate-bench decisions accepting identical exemption claims support the same treatment where Revenue identifies no factual or legal distinction. Tax authorities should not deny an otherwise lawful tax relief merely because the taxpayer was unaware of the entitlement. Taxable income and any consequential refund require recomputation after giving effect to the exemption.

Penalty imposed under Section 270A of the Income-tax Act and the consequential demand notice under Section 156 were challenged through writ jurisdiction under Article 226. An equivalent penalty order and consequential demand notice had already been quashed in a coordinate-bench decision. As the applicability of that decision was undisputed, the penalty order and consequential demand notice for the relevant assessment year were quashed in favour of the assessee.

Section 31(1) of the Insolvency and Bankruptcy Code makes an approved resolution plan binding on the corporate debtor, creditors, government and statutory authorities. Statutory tax claims relating to periods before plan approval are extinguished if they are not incorporated in the plan, and cannot subsequently be enforced through reassessment proceedings, assessment orders or demand notices, even where underassessment is later discovered. Where material facts are undisputed and the dispute concerns the legal effect of an approved resolution plan, writ jurisdiction may be invoked despite an available statutory appellate remedy.

Reassessment under Sections 148A(d) and 148 requires fresh tangible material distinct from issues examined in the original scrutiny. Reopening an assessment for a mutual-fund short-term capital loss previously scrutinised and accepted, based on the same material and survey allegations already addressed in binding identical-fact decisions, constitutes an impermissible change of opinion and is invalid.

Erroneous tagging of a Central Tax writ petition with an unrelated Income-tax Act batch resulted in application of an inapplicable ruling and section 151A. The resulting order contained an apparent error because the petition did not concern the Income-tax Act. The order was set aside, and the writ petition was restored for listing before the appropriate roster Bench.

Payments for live-feed broadcast rights limited to telecasting specified matches do not constitute royalty for income-tax purposes where the licensee receives no enduring benefit. Royalty character may arise if the rights permit recording, preservation, re-telecast, or other commercial exploitation of the feed beyond the stipulated event or licensed period. In the absence of those exploitation rights, payments for live-feed telecast rights fall outside royalty taxation under the Income-tax Act.

Replacement dies and moulds forming components of manufacturing machinery qualify as repair expenditure rather than independent plant. Research-related deductions, including qualifying work-in-progress, remain allowable on materially identical facts. Captive-power profits may support the applicable deduction on a notional-profit basis. Foreign agency commissions remain allowable where the facts and legal position are unchanged, including their characterization for income-tax purposes. UPS and voltage stabilizers used with computers attract depreciation as integral computer equipment at 60%, while a temporary parking shed attracts depreciation only at 10%.

Section 102 of the CGST Act and KGST Act permits rectification of an error apparent on the face of the record. An inadvertent typographical discrepancy may be corrected without a personal hearing where the correction does not alter the advance ruling, increase tax liability, or reduce admissible input tax credit. The hearing proviso is inapplicable in those circumstances. Rectification remains confined to the identified typographical error, leaving all other findings, discussion, and the ruling unchanged.

Section 107 of the CGST Act sets a three-month appeal period and permits the First Appellate Authority to condone delay only for one additional month on sufficient cause. As a statutory authority, it has no inherent power to extend that outer limit; equitable considerations or High Court directions confined to particular writ proceedings do not enlarge its jurisdiction. Where the Department has implemented an order restoring GST registration, enabled business continuation and return filing, estoppel and orderly administration prevent a later challenge seeking to reverse that position. Registration restoration consequently remains effective despite invalid condonation beyond the statutory limit.

Confiscation under Section 130(1)(ii) requires facts establishing deliberate tax evasion through unaccounted goods, not a short bona fide delay in recording genuine stock transactions. A pre-survey invoice, subsequent verification in regular books and statutory returns, and an accountant's temporary absence support the conclusion that delayed posting differs from non-accountal intended for clandestine removal. Physical-stock allegations based on visual approximation rather than standard weighment are also unreliable. Where assessment proceedings substantially accept the stock explanation and identify only minor discrepancies, treating the same transactions as both reconcilable and confiscable is legally inconsistent.

GST demands alleging wrongful input tax credit recredit must disclose the factual and legal basis of the charge in the show-cause notice, and adjudication must address the taxpayer's explanation through reasoned findings. Tax paid under the wrong IGST or intra-State tax head must follow the prescribed refund mechanism; unilateral recredit through GSTR-3B does not automatically create valid input tax credit. Payments actually made under the correct Central and State tax heads require recognition and reconciliation with the original payment and any recredit, preventing both double taxation and duplicate credit or refund. Interest requires findings of wrongful availment and utilisation, while penalty cannot stand independently where the underlying wrongful-credit charge fails.

GST exemption for municipal functions under Article 243W applies to services rendered by local authorities, not to an auction lessee commercially collecting weekly-market fees under tender conditions. Such collection arises from a contractual commercial right, and the contractor remains liable for applicable Central and State taxes. COVID-related lease waiver or refund of lease amounts and security deposit is not unconditional where GST and income-tax liabilities remain unpaid. Tender terms may permit adjustment of losses or expenditure against amounts payable to the licensee, requiring statutory dues to be cleared before lease-related relief or refunds are claimed.