Revision of assessment under Section 263 requires an order to be both erroneous and prejudicial to the interests of the Revenue. Third-party search information, without incriminating or corroborative material linking an assessee to alleged cash payments, does not establish either requirement where the Assessing Officer has examined purchase records, allotment details and bank statements and accepted the explanation. Explanation 2(a) does not permit revision merely because different inquiries are preferred; it applies where necessary inquiries or verification were absent. Revision cannot authorise a fishing or roving inquiry or replace a plausible assessment view. The conditions for revision were therefore not established, rendering the revision invalid.

Receipts reflected in seized material and related bank deposits concerned an unregistered Samiti operated by three individuals and were attributable to an association of persons rather than to one individual. Additions in the individual assessment therefore could not be sustained. Any assessment of those receipts, if warranted, must be made in the association's assessment in accordance with law, with arithmetic errors in the seized-material workings addressed.

Taxable income from an alleged immovable-property sale requires evidence of actual receipt of consideration and completion of transfer. The asserted transaction remained disputed before a civil court, while bank records showed no credit to the assessee, possession remained inconsistent with a completed sale, and mortgaged title documents restricted transfer without lender consent. Reliance on departmental information without addressing this contrary evidence did not establish taxable consideration. The addition was deleted because only real income, rather than notional or unreal income from an uncompleted or unproven transfer, is taxable.

Registration under the Rajasthan Public Trust Act, 1959 is not an essential condition for a charitable institution's registration under Section 12AB of the Income-tax Act, 1961. Where a trust already holds valid Section 12AB registration and no contrary material is produced, the absence of State public-trust registration does not justify refusing approval under Section 80G. The trust's application for Section 80G approval is therefore required to be granted.

Registration application rejection for incompleteness, non-compliance with notices, and lack of material establishing genuine activities was set aside. Fresh consideration was directed following the applicant's request for another opportunity to comply, after allowing a reasonable opportunity to cure deficiencies and furnish required information. Costs were imposed for the earlier non-compliance, and the application was restored for a fresh decision.

Unexplained investment addition under Section 69 was sustained because the claimed cash advance from a proposed agricultural-land sale was unsupported during assessment. The receipt and agreement were first produced in appellate proceedings without explaining their earlier absence. As the sale did not materialise and the advance was repaid after five years, the claimed cash source remained unproved under the Section 292C presumption.

Best-judgment assessment requires a profit estimate that is fair, honest and reasonably connected with available material and circumstances. A net-profit rate of 6.5% of gross receipts was sustained because no books of account or credible contrary evidence were produced. The rate took account of past assessment history, comparative gross receipts and the reduction from the Assessing Officer's original 8% estimate.

An alleged on-money addition under Section 69 cannot be sustained solely on an unverified third-party excel sheet and statements where no reliable material links the taxpayer to a cash payment. The Revenue must corroborate such evidence through vouchers, receipts, ledgers, signed documents, comparable transactions, or other assessee-specific incriminating material. Denial of cross-examination of persons whose statements are relied on further undermines the evidentiary basis. Where the declared consideration exceeds stamp-duty valuation and the burden remains undischarged, the addition is unsustainable and must be deleted.

Rectification orders under Section 154 are appealable under Section 246A of the Income-tax Act, 1961. Rejecting an appeal by relying on Section 246, without examining the rectification claim or the taxpayer's claim for the concessional tax rate under Section 115BAB on merits, is unsustainable. Internal allocation of a faceless appeal to the JCIT(A) rather than the CIT(A) does not prejudice the taxpayer. The first appellate authority must adjudicate the rectification and concessional-rate claims on their merits in accordance with principles of natural justice.

Section 90(2) gives a non-resident the benefit of a more favourable Double Taxation Avoidance Agreement rate over domestic tax provisions. Section 206AA, which prescribes higher tax deduction where PAN is not furnished, operates procedurally and does not override that treaty protection. Accordingly, royalty and fees for technical services paid to non-residents may be subject to tax deduction at the applicable beneficial treaty rate despite the absence of PAN, rather than the higher domestic withholding rate.

GST levy on affiliation fees charged by an educational board for granting affiliation is under consideration. The challenge relies on a prior ruling that characterises affiliation as a statutory and regulatory function outside the scope of taxable supply or, alternatively, as exempt. No determination on taxability has been made. Notice was issued, and the respondents were given time to obtain instructions on the applicability of the prior ruling.

Schedule II at 6% distinguishes bio-diesel other than that supplied to Oil Marketing Companies for blending with High Speed Diesel. It adds renewable energy devices and parts for their manufacture, including biogas plants, solar power-based devices and generators, windmills and wind-operated electricity generators, waste-to-energy devices, solar lanterns or lamps, ocean or tidal energy devices, and photovoltaic cells. When these goods are supplied with other goods and services, one of which is a prescribed taxable service, goods value is deemed to be 70% of gross consideration and service value 30%.

Goa GST exemption Schedule entry for tariff heading 1209 covers seeds, fruit and spores of a kind used for sowing. The exemption is confined to seeds intended for sowing and excludes seeds meant for any other use. The substituted entry takes effect from 1 October 2021.

Reverse-charge GST liability is extended to supplies of specified essential oils, other than citrus-fruit oils, by unregistered suppliers to registered recipients. The covered oils include peppermint oil and other mint oils, namely spearmint oil, water mint oil, horsemint oil and bergamot oil. Registered recipients become subject to the applicable reverse-charge mechanism from 1 October 2021.

Goa grants a time-bound concessional State tax exemption for specified COVID-19 medicines classified under Chapter 30. State tax is nil for Tocilizumab and Amphotericin B, while a concessional rate of 2.5% applies to Remdesivir, Heparin, Itolizumab, Posaconazole, Infliximab, Bamlanivimab and Etesevimab, Casirivimab and Imdevimab, 2-Deoxy-D-Glucose, and Favipiravir. The concessional treatment operates from 1 October 2021 through 31 December 2021, inclusive.

The table entry at serial number 1 is substituted to cover food preparations put up in unit containers for free distribution to economically weaker sections under government-approved programmes, and Fortified Rice Kernel (Premix) supplied for ICDS or similar approved schemes. Corresponding conditions replace "food preparations" with "goods" wherever occurring. The amendment takes effect on 1 October 2021.

Entry 19C under service classification 9965 grants a nil GST rate for satellite launch services supplied by the Indian Space Research Organisation, Antrix Corporation Limited, or New Space India Limited. The exemption is supplier-specific, contains no listed condition, and is deemed operative from 16 October 2020 within the Goa GST rate schedule.

Late-fee liability for delayed furnishing of FORM GSTR-10 is waived to the extent it exceeds two hundred and fifty rupees for eligible registered persons. Eligibility applies where a registered person failed to furnish FORM GSTR-10 by its due date but furnishes it during the period from 22 September 2020 to 31 December 2020. The waiver operates in respect of late fee payable for the delayed return filing.

FORM GSTR-8 filing time limit for e-commerce operators is extended for the December 2024 statement until 12 January 2025. The statement contains details of outward supplies of goods, services, or both effected through the operator. The revised time limit is deemed effective from 10 January 2025.

Time limit for furnishing FORM GSTR-7 for December 2024 was extended until 12 January 2025 for registered persons required to deduct tax at source. The extension applies to the return required under the Goods and Services Tax framework for tax deductors.