Cash deposits were accepted as explained only where cash-flow entries were supported by corresponding prior withdrawals. An opening cash balance lacked evidence of the preceding year's closing balance, and cheque payments recorded as withdrawals could not establish cash availability for subsequent deposits. Deposits matched by withdrawals made immediately beforehand were treated as supported. Interim deposits and agricultural expenditure remained unexplained, resulting in the addition being restricted to the unexplained components.

Cash deposits during the demonetisation period cannot be treated as unexplained money merely because of the timing of deposit when accepted business turnover in the same accounts provides an apparent source. Section 69A applies only after its statutory conditions are established through material showing an independent, non-business source or an abnormality in the business. Where receipts are accepted as turnover, assessment should ordinarily be limited to the profit element rather than a separate addition of gross receipts. A best-judgment assessment must be fair, material-based, and free from conjecture.

Interest on compulsorily convertible debentures remains eligible for allowance while the instruments subsist as debt and have not been converted or redeemed. Ind AS classification of a compound financial instrument partly as equity is a disclosure treatment that does not, by itself, recharacterise outstanding CCDs for transfer-pricing purposes; actual conversion or redemption requires verification. Likewise, no separate notional-interest adjustment arises on overdue associated-enterprise receivables where interest is uniformly not charged on comparable delayed receivables from unrelated customers. The same commercial policy establishes comparable conduct and renders the receivables adjustment unsustainable.

Section 92C(3) permits rejection of a transfer pricing analysis only where the data used to determine the arm's length price is unreliable or incorrect. Modification of comparability filters alone does not justify discarding a study when its functional analysis, tested party, databases, search methodology and contractual terms are undisputed. The arm's length price for software development services requires re-examination using the taxpayer's database, modified filters and accept-reject matrix. Delayed associated-enterprise receivables can require a separate interest adjustment unless aggregated in transactional net margin method margins after working-capital adjustment; associated-enterprise payables cannot automatically be set off against receivables.

Transfer-pricing method selection under Rule 10B depends on the tested party's functional profile. Product-replacement services involving custody and delivery of spares, nil-value supplies, a fixed cost markup, no control over customers or resale prices, and no material inventory or product risks indicate a captive service-provider profile rather than a trading function. TNMM is therefore appropriate for benchmarking that segment, while RPM is unsuitable because the segment does not undertake independent resale functions or bear trader-level risks. The functional analysis supports acceptance of TNMM for the product-replacement segment.

Substantial questions of law in an appeal confined to a miscellaneous-application order must arise from determinations made in that order. The finding that an Indian subsidiary was not a dependent agent permanent establishment remained unaltered because the software-sale transaction was accepted as a purchase-and-sale transaction and subjected to arm's-length-price determination. Challenges directed at that earlier, unmodified finding do not arise from an order modifying remand directions. The earlier order may be challenged separately in accordance with law.

Reassessment proceedings concerning domain-registration receipts were stayed pending further hearing. Prior determinations on the characterisation of those receipts, the absence of a permanent establishment, and earlier scrutiny assessments were relevant to the challenge. The reassessment action was prima facie considered inconsistent with objectivity, certainty and finality in tax adjudication. The High Court issued notice and stayed the reassessment proceedings pending the next hearing.

Section 152(3) preserves the pre-Finance (No. 2) Act, 2024 reassessment framework under Sections 147 to 151 where a third-party search was initiated between 1 April 2021 and 1 September 2024. For such searches, the pre-amendment Explanation 2(iv) to Section 148 continues to apply despite its later omission. The Assessing Officer is consequently deemed to possess information suggesting income escaping assessment and may issue a reassessment notice directly under Section 148 without first issuing a notice under Section 148A(b).

Internal comparables derived from audited segmental accounts should be preferred to external comparables under the Transactional Net Margin Method when they are available and suitable for determining the arm's length price. Reliability depends on sales being allocated using actual invoice-level data, common expenses being apportioned on a rational basis, and the allocation methodology being supported by chartered accountant certification. Where these conditions are satisfied and the supporting factual findings are not perverse, internal comparables support deletion of an upward transfer-pricing adjustment.

Transfer-pricing comparables may be screened through a rational turnover filter where differences in scale materially affect pricing. Selection must consider functions, assets, risks and material turnover differences. A software-product developer that owns intellectual property or develops and markets products is functionally distinct from a captive software-development service provider and should be excluded from its comparable set. Where the transfer-pricing officer has completed the comparability analysis, directions excluding specified entities require effect to be given to those exclusions only; they do not require a fresh arm's-length-price or comparability exercise.

Reassessment proceedings based on discrepancies between Risk Management Strategy portal figures and earlier assessment and payee records require disclosure of information necessary for reconciliation at the inquiry stage under Sections 148A(1) and 148A(3) of the Income-tax Act, 1961. Where the relevant details were not supplied and the inquiry remained limited, the matter must return to the notice stage, allowing an additional response and personal hearing before a fresh order. The correctness and legality of initiating reassessment proceedings remain open.

Statutory limitation governing GST detention penalties requires the proper officer to issue a penalty notice within seven days of detention or seizure and pass the penalty order within seven days after service of that notice. The mandatory wording, fiscal nature of the law and coercive consequences of detention and penalty require strict compliance. Where undisputed record dates establish that the order was made substantially beyond the prescribed period, a limitation objection may be raised without being treated as an impermissible new ground. The delayed penalty order is time-barred, illegal and without jurisdiction.

Revisionary proceedings under the Karnataka State GST Act remain within the three-year limitation period after excluding the pandemic-related period from 15 March 2020 to 28 February 2022, which applies to judicial, quasi-judicial and departmental proceedings. Penalty for movement of goods was restored because the goods were unloaded at a location not covered by the available tax invoice and e-way bill. Required delivery documents were generated only after interception, and the asserted technical glitch was unsupported by evidence. These circumstances established a wilful attempt to evade tax rather than a minor procedural lapse, leaving the statutory penalty operative.

Section 129(3) mandates issuance of a penalty order within seven days of service of notice. In fiscal matters, this statutory timeline requires strict compliance. Failure to issue the order within that period, including a delay of 445 days after notice, vitiates the detention and penalty proceedings. Such a penalty order is void ab initio and a nullity, and an appellate order affirming it cannot stand.

Unaccounted or excess goods discovered during a GST survey must be dealt with through tax determination provisions, rather than confiscation proceedings, where prescribed accounts have not been maintained. Tax on such goods is to be determined under the applicable demand provisions. A fine imposed through confiscation proceedings cannot survive independently once the underlying confiscation proceedings and associated penalty have been set aside. Accordingly, restoration of the fine alone is not maintainable after the foundational proceedings fail.

The prescribed monetary threshold of Rs. 20 lakh under the Uttar Pradesh GST framework restricts departmental appeals involving lower disputed tax amounts. Such an appeal is not maintainable for admission unless the Revenue establishes a recognised exception to the threshold. General approval or authorisation by the Commissioner does not, by itself, demonstrate compliance with an exception where the record lacks a specific and reasoned exercise of residual power under section 112(3). The statutory right of appeal remains subject to the binding monetary-limit framework governing departmental litigation.

Departmental GST appeals are subject to prescribed monetary limits under the statutory litigation-management framework. In penalty-only disputes, the relevant amount is the penalty imposed. A departmental appeal below the applicable threshold is not maintainable unless the Revenue pleads and establishes a recognised exception. Commissioner approval or authorisation alone does not satisfy that requirement. Where reliance is placed on a residual exception, the Revenue must produce material demonstrating a specific recorded exercise of discretion. Failure to meet the threshold condition cannot be cured by examining the merits of the underlying dispute.

Departmental GST appeals are subject to the Rs. 20,00,000 monetary threshold prescribed under the Uttar Pradesh GST litigation policy authorised by section 120. Where tax is disputed, the aggregate tax demand determines threshold applicability; a Rs. 1,90,080 demand falls below it. Revenue may proceed only by specifically substantiating a prescribed exception. Commissioner approval under section 112(3), without a recorded, case-specific and reasoned exercise of residual discretion, does not establish such an exception. Compliance is a threshold condition for admission and maintainability, so a below-threshold departmental challenge cannot be examined on merits; the underlying tax dispute remains undecided.

The amended Rule 89(5) GST refund formula, including input tax credit on input services, is treated as curative and applicable to timely refund or rectification applications for earlier tax periods, despite a contrary departmental circular. Supplementary or differential refund claims remain maintainable where substantive eligibility and quantum require verification; neither Section 54 nor Rule 89 bars them merely because an original claim was processed. A later notification cannot, through an administrative circular, deny refund of otherwise eligible input tax credit accumulated before its effective date. The notified exclusion from limitation computation keeps the claims timely, and eligible differential refunds remain subject to arithmetical verification.

Anti-profiteering calculations under the CGST framework require the benefit of net available input tax credit to be passed to recipients through commensurate price reductions. Unutilised input tax credit that has been reversed is excluded when determining the additional credit benefit and any amount required to be returned. Amounts not passed on must be returned to eligible recipients with interest at 18% from collection until repayment. The penalty provision for anti-profiteering applies only from its commencement and cannot be imposed for conduct occurring before that date. Liability for the earlier period is therefore limited to restitution of the net credit benefit and statutory interest.