A penalty for concealment of income or furnishing inaccurate particulars cannot be sustained where the notice under section 274 retains both statutory limbs without identifying the specific charge. Failure to strike off the inapplicable limb leaves the allegation ambiguous, denies the assessee clear notice and an effective opportunity to defend, and vitiates the penalty proceedings. The penalty was therefore treated as invalid and deleted.

Cash deposits assessed as unexplained income under Section 68 were supported by a cash-flow statement, prior income records, loan documents, bank records, household and education expense evidence, and the spouse's returns. The available material established an opening cash balance, while the balance of the deposits was explained through the assessee's, spouse's and agricultural income. An opening cash balance brought forward from an earlier year cannot be taxed in the relevant year. Where supporting evidence is not specifically rebutted, the entire cash deposit cannot be treated as unexplained on surmises and conjectures; the addition was therefore deleted.

Counsel-related communication failure, supported by affidavit and untainted by deliberate delay, constituted sufficient cause for condoning a 285-day delay in filing an appeal. An ex parte appellate decision made when the assessee lacked representation required fresh adjudication to ensure a meaningful opportunity to submit factual material and explanations. The additions and disallowance remained open for independent determination on merits, and the matter was restored for fresh appellate consideration after due hearing.

Disclosed commodity-trading profit accepted as business income cannot be treated as unexplained money where seized cash is explained by that profit and no contrary material disproves the explanation. The amount formed part of the return under profits and gains of business or profession, and the returned income had been accepted. As the income was not characterised as non-business income and its stated source was not rejected on evidence, the conditions for applying the special-rate provision for unexplained money were not satisfied. The profit is therefore assessable as disclosed business income rather than unexplained money.

Disallowance of expenditure relating to exempt income cannot exceed the exempt income earned, even where the prescribed computation method produces a higher figure. For both assessment years, the computed disallowance exceeded the respective exempt income and must therefore be restricted to that exempt-income amount. This limits the disallowance to the actual tax-exempt income earned, in favour of the assessee.

Reassessment cannot be validly initiated on the premise that stock-option transaction profit escaped assessment where substantially corresponding commodity-dealing profit was already disclosed in the profit and loss account, computation of income and return. The alleged escaped income had therefore already been offered to tax and assessed on the basis of the return. The reopening and consequential reassessment order were quashed in favour of the assessee.

Employees' PF/ESI contribution disallowance may be adjusted while processing a return under Section 143(1) where the return material itself establishes a prima facie disallowance. The statutory adjustment therefore remains valid. TDS credit relating to an amalgamating company requires factual verification of whether tax was deducted on that company's behalf. Upon such verification, the amalgamated company is entitled to the corresponding TDS credit.

Recorded cash sales supported by purchase invoices, stock records, payment details, VAT disclosures and supplier confirmations explain demonetisation-period bank deposits; absent proof that the underlying purchases or sales were bogus, the deposits cannot be treated as unexplained cash credits. General investigation material alleging that suppliers provide accommodation entries does not disprove transaction-specific purchases where contemporaneous records, corresponding sales and supplier confirmations remain unrebutted. Adverse third-party statements cannot support additions when requested cross-examination is denied. Once purchases are accepted as genuine, estimating a profit element on those purchases lacks a legal basis. The business transactions and resulting cash balance therefore eliminate both additions.

Employees' provident fund contribution deposited one day after the prescribed date remained deductible where the delay resulted from technical glitches on the provident fund portal. Material on record established the portal-related cause, identical decisions on such delays supported deduction, and no contrary material was produced. The disallowance was therefore required to be deleted.

Internal inconsistency in return entries can constitute an incorrect claim apparent from information in the return, permitting adjustment during processing under section 143(1). Where interest sub-fields were shown as nil but the aggregate interest column disclosed an amount, the interest claim was capable of adjustment. Interest expenditure recorded in audited accounts but entered in an incorrect return column remains subject to verification of applicable tax-deduction compliance and any resulting disallowance under section 40(a)(ia). Following verification, the expenditure may be allowed or disallowed accordingly.

Transfer-pricing benchmarking of captive software development service providers requires turnover-based and functional comparability. Entities with turnover exceeding ten times that of the tested party, diversified operations, product activities, or materially different functional profiles should be excluded, while suitable comparables should be included for fresh arm's-length computation. A separate adjustment for interest on delayed trade receivables requires verification and should not be made where the delay is already reflected in a working-capital adjustment, as this would duplicate the adjustment. Penalty proceedings require consequential reconsideration after recomputation of the underlying transfer-pricing adjustment.

Non-filing of a return attracts statutory deemed concealment even where income is later disclosed in response to a reassessment notice and accepted in reassessment. Acceptance of the returned income does not remove concealment because the income would otherwise have escaped assessment. For computing tax sought to be evaded, tax deducted at source and self-assessment tax paid before issue of the reassessment notice must be reduced from tax on the assessed income. Penalty is therefore leviable, subject to computation after allowing those eligible tax credits.

Interest expenditure on borrowings used to advance funds generating taxable interest income is deductible under Section 57(iii) where a reasonable and proximate nexus exists between the expenditure and the income-earning purpose. The relevant test is the dominant purpose of incurring the expenditure, not whether income arises in the same accounting period. Where accounts establish that borrowed funds were advanced to entities from which interest income was earned and offered to tax, and the remaining interest cost was capitalised, the corresponding interest expense is allowable. The expenditure's genuineness and factual linkage must not be disproved.

Under the CGST and KGST Acts, each tax period must be subjected to separate proceedings under the statutory framework for tax determination. Clubbing multiple tax periods or financial years into a single composite show-cause notice exceeds the authority provided under the relevant provisions. Such a notice is invalid for want of jurisdiction, and adjudication or appellate proceedings based on it cannot be sustained. The defect does not prevent initiation of fresh proceedings separately for each relevant tax period in accordance with law.

Anticipatory bail was sought in allegations of fraudulent availment and passing of fake input tax credit without actual supply of goods or services. The allegations concerned non-payment of GST on substantial transactions and were characterised as an economic offence involving a cognizable and non-bailable offence. The Supreme Court dismissed the special leave petition without interfering with the High Court's judgment and order.

Imports of clear float glass, 4 mm to 12 mm, under ITC (HS) codes 70051090 and 70052990 move from the Free to Restricted category. Imports remain free where the CIF value is at least Rs.34,000 per MT, creating a minimum import price condition. Advance Authorisation holders, EOUs and SEZ units are exempt from this condition if the imported inputs are not sold in the Domestic Tariff Area. The minimum import price condition applies for one year from publication.

Mutual fund registration applications are consolidated into a revised single Form A, replacing the separate forms previously required for in-principle sponsor approval and final registration. The two-stage registration process continues: Stage I requires sponsor identification, ownership, financial strength, eligibility-route compliance, regulatory history, governance and policy disclosures; Stage II requires AMC particulars, governance, infrastructure, business planning, investor-service, technology, continuity, compliance and conflict-management information. Sponsors and AMCs must provide prescribed annexures, supporting records and self-certified declarations confirming that submitted information is true, complete and compliant. Existing conditions under the Master Circular remain unchanged.

Administrator denotes the Administrator identified under section 2(a) of the Unit Trust of India (Transfer of Undertaking and Repeal) Act, 2002. Under the Income-tax Act, 2025, this meaning applies for tax deduction at source and tax collection at source purposes. Under the Income-tax Act, 1961, the same expression carries the meaning assigned by clause (a) of section 2 of that enactment.

Transportation services for goods sent to a destination outside India, where supplier and recipient are both in India, have their place of supply at the foreign destination. The supply is inter-State, and IGST is chargeable because the supplier is in India while the place of supply is outside India. The Indian recipient may avail input tax credit of the IGST, subject to general eligibility conditions, apportionment rules and blocked-credit restrictions. The supplier must report the place of supply in GSTR-1 using code "96-Foreign Country".

Punjab SGST appellate filing timelines under section 112 are revised, with the earlier notification superseded subject to preservation of prior actions and omissions. Appeals against orders communicated before 1 May 2026 and applications concerning orders passed before 1 February 2026 may be filed before the Appellate Tribunal up to 31 July 2026. Later appeals remain subject to a three-month period from communication, while later applications remain subject to a six-month period from the order date. The revised timelines are deemed effective from 30 June 2026.