Cash advances received in connection with the transfer of immovable property constitute a specified sum and must comply with the prescribed mode of receipt under section 269SS. Section 273B prevents penalty under section 271D where the recipient proves reasonable cause. A genuine sale agreement, completed transfer, confirmed transaction, substantial secured housing liability, modest income, and the need to raise funds to repay that liability may establish bona fide financial exigency. In the absence of evidence of fictitious dealings, undisclosed-money introduction, or tax evasion, reasonable cause makes the penalty unsustainable.

For assessment year 2012-13, section 54 permitted exemption for investment in adjoining flats that were acquired and intended to function as one residential accommodation; the later restriction to one residential house in India did not apply. Capital-gains computation for a property comprising land and a building must include indexation of the accepted allowable cost of the building, rather than indexation of land alone. Sufficient cause for delayed filing may be established by bona fide circumstances, including advanced age, difficulty accessing electronic communications, and prompt action upon learning of the appellate order.

Section 69 additions for capital introduced and unreconciled bank credits require verification of the taxpayer's explanation and supporting bank records. Identified sources, including personal-bank funds, loan repayment, maturity proceeds and FD/OD withdrawals, must be reconciled with confirmations and documents; where substantiated, the additions cannot survive. GST late fee for delayed tax payment is deductible business expenditure because it compensates for delay and is not incurred for an offence or a purpose prohibited by law under Explanation 1 to section 37(1).

For proceedings under section 153C against a person other than the searched person, the relevant search date is the date when the jurisdictional Assessing Officer receives seized material or records satisfaction. The statutory assessment block is calculated by including the assessment year relevant to that date. Even if the searched person's satisfaction-note date is used, Assessment Year 2009-10 falls outside the permissible period. Consequently, the section 153C notice, assessment order and consequential demand are time-barred and invalid.

Tax-evasion prosecutions under the Income-tax Act depended on the assessment order relating to the relevant return. Once that order was set aside and remanded for fresh assessment, the prosecution lost its underlying foundation and the complaint was not maintainable. The resulting convictions and sentences were set aside, and the accused were acquitted of all charges.

Sufficient cause for delayed filing before the Commissioner (Appeals) requires a bona fide, adequately supported explanation covering the material period of delay. Bereavement of counsel may explain delay only until counsel resumes work; a later illness must be substantiated by medical or other supporting evidence. An assessee's own non-cooperation can defeat a claim that counsel alone caused the delay. In an appeal under Section 260-A, concurrent factual findings refusing condonation are not reappraised unless perverse, unsupported by material, or made in disregard of relevant material; failure to establish sufficient cause raises no substantial question of law.

Section 148A requires an assessee to receive an opportunity of personal hearing before a determination is made that reassessment notice should be issued, where such hearing has been sought. Service of a show-cause notice and consideration of a written response alone do not fulfil that requirement. Denial of the requested hearing breaches the statutory mandate and principles of natural justice, invalidating the determination. Fresh reassessment proceedings may be initiated only after affording the assessee a personal hearing.

For searches initiated on or before 31 March 2021, the statutory saving under section 149 preserves the search-assessment framework under sections 153A and 153C. Material found in such a search must be addressed through that framework rather than reassessment proceedings under sections 148A and 148. Reassessment may proceed on material independently obtained after the search only where the applicable statutory conditions are met; it cannot substitute the prescribed search-assessment route for incriminating search material.

Registration under Section 12AB requires assessment of a trust's objects as a whole to determine whether they advance public charitable purposes. Objects concerning sectoral development, research, training, information dissemination, professional standards, public information, community development and social welfare may benefit the public at large where they extend beyond society members and do not involve religious activities. Section 13(1)(b) addresses the availability of exemption under Sections 11 and 12 and should ordinarily be examined during assessment on the material then available. It cannot, by itself, justify refusal of registration at the initial registration stage.

Section 254(2) confines ITAT rectification jurisdiction to correcting mistakes apparent from the record and does not permit review on merits or reappreciation of matters already decided. Reliance on new considerations relating to distributor confirmations and cash-receipt patterns, when those matters neither formed part of the rectification grounds nor the original appellate order, falls outside that limited jurisdiction. Rejection of a rectification application on such new grounds exceeds the permissible scope of rectification.

Reopening of a completed scrutiny assessment after four years requires the assessee's failure to make a full and true disclosure of material facts necessary for assessment. Where unabsorbed depreciation was disclosed, no depreciation was claimed for the relevant year, and delayed TDS deposit had been examined and dropped in the original proceedings, reassessment cannot be used to review or revisit those matters. The notice under Section 148 and the consequential reassessment order were invalid and quashed.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer examines written explanations on CENVAT credit valuation, excise-duty refund and additional depreciation, and adopts a legally permissible view, revision cannot rest merely on the Commissioner's preference for another view. Lack of detailed reasoning in the assessment order alone does not establish error or prejudice. On these principles, revision was invalid because the relevant matters had been considered and no addition was warranted on their merits.

Internal TNMM acceptance in determining arm's length pricing is governed by the transfer-pricing framework in sections 92 to 92C and Rule 10B. Where binding precedent has already resolved an identical challenge arising from the same impugned order, the issue is fully covered and does not raise a substantial question of law. The transfer-pricing adjustment deletion therefore remains unaffected.

Denial of an assessee's requested and acknowledged video-conference personal hearing breaches the mandatory personal-hearing requirement under the faceless assessment procedure. Where the assessment is completed without granting that hearing, despite a request made in response to the show-cause notice, the assessment order and consequential tax demand cannot be sustained. The requirement protects the assessee's opportunity to be heard before finalisation of the assessment.

Duly accounted sales receipts recorded in audited books, supported by sales and quantitative details, and accepted as income cannot also be treated as unexplained cash credits. Where the corresponding sales are undisputed and the profit element has already been offered to tax, a further addition for the same receipt would tax the amount twice. Section 68 therefore does not apply to an accepted sales receipt merely because it is reflected as a credit entry.

Section 145(3) permits income estimation after rejection of books of account, but the estimate must have material support and relevant internal or external comparables. A fixed net-profit estimate for steel trading cannot rest on assumptions where sectoral margins are materially lower and no comparable data supports the rate. Consistency with comparable prior-year determinations, absent distinguishing facts, supports sustaining the appellate estimate as a factual finding. Fact-supported estimation does not give rise to a substantial question of law under Section 260A.

Section 250(6A) contemplates, where possible, hearing and deciding income-tax appeals within one year from the end of the relevant financial year. The qualification "where it is possible" does not permit indefinite postponement. Prolonged pendency, including a first appeal pending for over six years, constitutes genuine hardship warranting priority disposal. Such an appeal should be decided within three months of receipt of the order.

Section 151 reassessment approval must be granted by the authority competent under the limitation framework applicable on the relevant date. Once the three-year period has expired, approval by a lower specified authority is jurisdictionally defective, and additional time to respond to a notice cannot cure that defect. The Finance Act 2023 proviso changing the computation for identifying the approving authority operates prospectively and does not retrospectively validate an invalid sanction. Third-party survey material can support reopening only where it establishes a direct, live nexus with the assessee; loose papers and statements lacking identifying details or transactional connection are insufficient.

Provisional reversal of input tax credit reported in Table 4(B)(2) of GSTR-3B does not, without a quantified statutory demand or unequivocal admission, establish self-assessed GST liability. A pending investigation into an alleged stock shortage is not a determination of tax payable and cannot alone justify retaining the reversed amount as tax. A later demand order under separate challenge cannot retrospectively validate the original grounds for rejecting refund or characterise the earlier reversal as payment towards that demand. Refund remains subject to satisfaction of the applicable statutory requirements.

GST on hotel accommodation hired by the Department of Home requires the accommodation proprietor to obtain GST registration and remit the tax to the GST authorities. The hiring Department must bear the prescribed GST separately, in addition to the rent payable for the accommodation. The arrangement therefore treats GST as an additional charge over the stipulated rental amount while placing registration and remittance obligations on the service provider.