Bharti Airtel has discontinued prepaid plans combining 1.5 GB daily data allowances with unlimited calling, directing subscribers towards higher-priced plans with expanded data access, including unlimited 5G data. The restructuring reduces low-priced unlimited-data offerings and changes the pricing architecture for customers using discontinued mid-tier plans. Management links tariff repair to differentiated mobile-plan categories and sustained average revenue per user growth.

Revisionary jurisdiction cannot treat an assessment order as erroneous and prejudicial to the interests of Revenue solely because the Assessing Officer did not initiate concealment-penalty proceedings or record satisfaction for doing so. Penalty proceedings are separate and independent from assessment proceedings; therefore, their non-initiation does not vitiate the assessment order. A revisionary direction requiring initiation of penalty proceedings on that basis is invalid, and the issue stands in favour of the assessee.

Unexplained cash credit for Assessment Year 2017-18 was not sustained because the unsecured-loan agreement was executed in financial year 2017-18, relevant to Assessment Year 2018-19. Contractual rights and liabilities arose only on execution of that agreement, and the related interest income was declared in the subsequent year. The March 2017 cheque date alone did not establish that the loan transaction accrued during the assessment year under review. The cash-credit addition was therefore deleted in favour of the NBFC assessee.

Permanent registration under section 12AB cannot be refused merely by treating a trust's activities as advancement of general public utility and invoking the proviso to section 2(15). Imparting education and providing relief to the poor fall within recognised charitable purposes and are not classifiable as general public utility activities. Even where the proviso to section 2(15) may apply, its applicability is examined during assessment proceedings and does not independently bar registration. A trust conducting genuine charitable activities is therefore eligible for registration under section 12AB.

Section 10A requires parity between export turnover and total turnover: any foreign-exchange gain excluded from export turnover must also be excluded from total turnover, because export turnover forms part of total turnover and asymmetric exclusions distort the deduction formula. Foreign-exchange results from forward contracts require verification of their nexus with export proceeds. Gains or losses from derivative contracts qualify as hedging results only where the contracts cover foreign-exchange risk relating to export proceeds. Where that nexus is established, the Section 10A computation should consider only the net profit or loss from the hedging transactions.

Rule 46A permits admission of additional evidence where sufficient cause is recorded and the Assessing Officer receives an effective opportunity to examine and rebut it. For unsecured loans and fresh trade credits, confirmations, tax returns, bank statements, ledger accounts and invoices may establish identity, creditworthiness and genuineness; unsupported suspicions about lenders or their immediate funding source do not sustain section 68 additions. Section 68 does not apply to brought-forward loan or creditor balances. Once principal loans are accepted, related interest disallowance cannot survive. Partners' capital additions fail where actual contributions are supported and interest credits are merely accounting entries without fund inflow.

Cash-deposit source claims based on jewellery sales, jute and jute-bag sales, and commission receipts require fresh verification where supporting material was not produced earlier or remains insufficient. Jewellery-sale evidence must be examined, while jute transaction samples must be tested with the claimed commission receipts and the nature of underlying transactions. The commission basis requires confirmation from identified persons and supporting documents. The source claims were remitted to the Assessing Officer for fresh verification after providing the assessee adequate opportunity.

Section 14A read with rule 8D does not permit disallowance of expenditure where no exempt income was earned during the relevant assessment year. Since the investments did not generate exempt income, no expenditure could be regarded as incurred in relation to income excluded from total income. A CBDT circular supporting disallowance despite the absence of exempt income cannot override the statutory provision or its judicial interpretation. Accordingly, the section 14A disallowance computed under rule 8D was unsustainable and deleted.

Duplicate entries in Individual Transaction Statement data for salary income and professional or technical-fee receipts require verification before additions are sustained. Reconciliation identified corresponding receipts appearing twice, raising the possibility that certain income had been taxed twice. The Assessing Officer must conduct limited verification of the alleged duplication, allow the assessee an opportunity to be heard, and recompute the correct taxable income.

Expenditure by a charitable trust for the benefit of a person specified under section 13(3), for which section 11 exemption is unavailable, must be excluded from the expenditure claimed as charitable application of income. It is not to be separately added to total income. Where the resulting net income is absorbed by permissible accumulation, total income remains nil. Interest received on a corpus donation carrying a direction to provide medical assistance to patients recommended by the donor does not alter this computational treatment where the donor is a specified person.

Cash-deposit addition for alleged unexplained deposits was unsustainable where documentary material evidenced that the assessee's wife received funds under an agreement to sell, transferred them to the assessee, and the amount was deposited in the bank account. Non-registration and subsequent cancellation of the agreement did not, by themselves, disprove the receipt. In the absence of positive evidence contradicting the explanation, the addition was deleted; only a small balance amount remained unexplained.

Appeals filed by a purported legal representative of a deceased assessee are maintainable only where the applicant proves management of the deceased's estate, intermeddling with the estate, or that proceedings have been initiated against the applicant as legal representative under the Act. Mere assertion of representative status is insufficient. Without material establishing any of these circumstances, the applicant lacks demonstrated competence to maintain the appeals. Such appeals may be treated as premature, while permitting fresh filing once representative status is substantiated.

Section 153C requires a valid, actionable satisfaction based on seized material that pertains to the other person and can affect income determination for the relevant assessment year. A consolidated satisfaction note may be used, but it must identify the seized documents, relevant transactions and assessment-year-wise nexus, demonstrating application of mind. An identical generic note that omits these particulars fails the jurisdictional requirement. Such satisfaction is non est in law, rendering the assessment initiated on its basis unsustainable.

Section 153D requires informed, independent approval for each assessee and assessment year before assessments under Section 153C are finalised. Placing only draft assessment orders before the approving authority, while issuing a consolidated approval for multiple years and asserting review of case records, does not demonstrate consideration of the relevant records, seized material and year-specific draft orders. A mechanically issued consolidated approval therefore fails the statutory requirement. The approval covering multiple assessment years was invalid, resulting in the quashing of the Section 153C assessments for the relevant years.

Section 153C requires satisfaction linking seized material to the relevant assessee and each assessment year. A sale agreement dated 28.08.2018 could at most relate to Assessment Year 2019-20 and did not connect with earlier years. Recording one consolidated satisfaction note for Assessment Years 2013-14 to 2019-20, without separate year-wise satisfaction, was treated as insufficient to assume jurisdiction. On that basis, the Section 153C proceedings, consequential notices and assessments for all covered years were described as invalid and quashed in favour of the assessee.

Prior sanction for an order under section 148A(d) and notice under section 148 is jurisdictional and must be obtained from the authority specified under section 151 based on the elapsed period. For assessment year 2016-17, the applicable three-year period, including the COVID-19 relaxation, expired on 30 June 2021. Approval granted on 27 July 2022 therefore required sanction from the higher specified authority under section 151(ii), not the Principal Commissioner. The proviso introduced from 1 April 2023 did not apply to the order and notice issued in July 2022. Sanction by an incompetent authority rendered the reassessment proceedings invalid.

Reassessment beyond three years under Section 149(1)(b) requires material showing escaped income of the prescribed threshold represented in the form of an asset. Alleged bogus purchases are revenue items and do not satisfy that condition unless they result in an identifiable asset recorded in the assessee's balance sheet. As no material or allegation established that the purchases created such an asset, the reassessment notice and consequential reassessment were invalid, and the bogus-purchase addition was deleted.

BSNL VRS-2019 ex-gratia compensation is treated as retrenchment compensation eligible for full exemption under Section 10(10B), despite an earlier exemption claim under Section 10(10C). The exemption claim may be raised through a revised computation during appellate proceedings where it was not made in a revised return. Delays in filing first appeals by similarly placed employees may be condoned where lack of awareness, incorrect professional advice and parity with favourable decisions establish sufficient cause. The Assessing Officer must verify eligibility for both assessment years, grant the exemption where due, and determine resulting tax liability or refund.

Wind turbine generators assembled and erected on foundations qualify as movable goods where they can be dismantled, relocated and sold without damage. Applying the tests of nature and object of annexation, intention, functionality, permanency and marketability, attachment to the foundation serves stable and efficient operation rather than beneficial enjoyment of the foundation. Although the foundation remains embedded and immovable, the generators are not permanently annexed to it. Their supply together with associated services therefore constitutes a composite supply, rather than a works contract relating to immovable property.

The sealing of a tax consultancy office following a search and seizure is challenged on the ground that the Superintendent of State Tax lacked legal authority to seal the premises. The High Court issued notice to the State respondents, returnable within two weeks. As counsel accepted notice for all respondents, no formal notice was required; the petitioner must provide additional writ-petition copies within three working days. No determination on the legality of the sealing has been made at this stage.