Section 153C cannot be invoked against an other person where the jurisdictional satisfaction is recorded after 1 April 2021, even if the underlying search occurred earlier. Recording satisfaction is the relevant jurisdictional event. Where it arose after the Finance Act 2021 reassessment framework became applicable, reassessment action had to comply with Sections 147 and 148. Notices issued and consequential proceedings commenced under Section 153C in those circumstances lacked jurisdiction and could not be sustained.

Section 56(2)(vii)(b) applies only where the acquired property is a capital asset. Agricultural land that falls outside the definition of a capital asset is therefore outside the scope of the provision, even where its stamp-duty value exceeds the purchase consideration. As the land's agricultural character was undisputed, the difference between the purchase price and stamp-duty value was not taxable as income from other sources. The addition based on that difference was deleted.

Short-term capital loss on the sale of unlisted shares cannot be disallowed merely because it reduces tax liability where the underlying transactions are genuine. Banking records, share-transfer documents and company registration established the purchase and sale, while no material showed a pre-arranged arrangement or lack of commercial substance. The sale price to a related party exceeded the price paid for comparable shares acquired by another family member. Genuine tax planning remains distinct from tax evasion; consequently, the loss disallowance and corresponding addition were deleted.

Section 249(4)(b) requires a non-filer to pay an amount equal to advance tax payable before pursuing an appeal, unless the Commissioner (Appeals) grants exemption on good and sufficient reason. Advance-tax liability under Section 209(1) depends on computation by the assessee or Assessing Officer. Where neither has computed advance tax, a claim of no taxable income and therefore no advance-tax liability cannot be summarily rejected. The assessee must have an opportunity to establish that Section 249(4)(b) does not apply or to seek exemption under its proviso. Dismissal for non-compliance was set aside for reconsideration of admissibility and, where appropriate, merits.

Interest on refunds of excess self-assessment tax is a substantive, non-discretionary statutory entitlement when appellate exclusion of gains creates the excess payment. Where the refund is not within specifically enumerated refund categories, interest runs from the date the excess tax was paid under the applicable refund-interest framework. The later amendment concerning self-assessment tax does not negate entitlement for the earlier period. Interest is payable from the payment date until 1 June 2016, with interest thereafter already paid.

Rule 11UA permits valuation of unquoted preference shares through a report from either an accountant or a merchant banker; an independent valuer's report is not exclusively required. A valuation certificate already furnished during first appellate proceedings is not additional evidence for Rule 46A purposes merely because it is relied upon before the Tribunal. Fair market value under Section 56(2)(viia) must follow the prescribed statutory valuation method. An isolated third-party share transaction cannot displace valuation evidence based on audited financial statements and applicable redemption terms. Statutory valuation evidence supported the stated preference-share consideration within the applicable fair-market-value parameters.

Revision under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Inquiry and verification by the Assessing Officer into depreciation, foreign-agent commission and employment-deduction claims, including verification supported by Form 10DA, showed application of mind. In the absence of an identified flaw in the taxpayer's explanations or in the verification undertaken, alleged inadequacy of inquiry did not satisfy the conditions for revision. The Section 263 revision was therefore unsustainable, with no substantial question of law arising.

Revisionary jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the assessee has disclosed material relevant to capital-gains computation and the Assessing Officer verifies that material before consciously accepting the explanation, revision cannot be based solely on a different view of the inquiry required or computation preferred. The assessment view must be unsustainable in law for revision to apply. On these principles, invocation of section 263 was impermissible and the issue was resolved in the assessee's favour.

Unexplained-investment additions under Section 69B require material evidence beyond an uncorroborated third-party document alleging cash on-money payments. Absence of independent inquiry into land values or other evidence establishing payment makes the addition unsustainable. The Section 132(4A) presumption applies to the person searched and to search-and-seizure proceedings; it cannot support a regular assessment against a person who was not searched. Consequently, deletion of the unexplained-investment addition remained undisturbed.

Two-zero decoding of figures on pages 4 and 5 of Annexure B-3 was supported by the equipment costs, withdrawals, cash position and capital investment, while a one-zero decoding lacked an equivalent factual basis. The resulting undisclosed-profit addition was restored on that basis. Entries in Annexures B-1 and B-2, apart from those pages of Annexure B-3, had already been assessed in the firm's hands. As the individual assessee lacked the financial capacity to undertake transactions of the reflected scale, additions for unexplained investment and undisclosed profit in the individual assessment remained deleted.

Registrar of Companies fees paid for increasing share capital qualify for amortisation under section 35D(2)(c)(iv) of the Income-tax Act. Expenditure connected with the issue of shares and public subscription is not confined to the specifically listed underwriting commission, brokerage, or prospectus-related charges. The comma after "issue" supports a broader reading that includes fees incurred for issuing share capital. Issuance of shares to a holding company does not affect eligibility. The expenditure is therefore allowable for amortisation.

Section 260A confines appellate review of factual findings to instances of perversity, absence of supporting evidence, or legal error. Rejection of books of account under Section 145(3), when founded on seized material and affirmed after appraisal of records, remains a factual determination not subject to reassessment merely because a different view is sought. Consequential income estimation and acceptance or restriction of fee-refund credit similarly remain factual matters unless a substantial question of law arises. Fee-refund relief falls within the Tribunal's determination where the Revenue challenges related addition relief and the assessee contests the sustained addition through a cross-objection.

CBDT Circular No. 11 of 2020 concerning residential-status consequences for Indian seafarers unable to leave India during the COVID-19 pandemic was challenged, alongside a request for a compassionate tax policy granting exemption where their Indian stay exceeded 182 days in a financial year. The respondents were asked to consider the representations sympathetically, with reference to specified judicial decisions, and to take an appropriate decision within four weeks.

GST exemption for psyllium seeds as fresh or chilled goods depends on their condition at the time of supply. Raw psyllium seeds classified under Heading 1211, when stored in dry and ventilated godowns and supplied without evidence preserving their fresh condition, are treated as dried rather than fresh. Consequently, they cannot claim the fresh-seeds exemption or the exemption for goods of seed quality. Dried psyllium seeds under Heading 1211 fall under the applicable rate entry and attract GST at 5%. The decisive principle is that a conditional fresh-goods exemption is tested at supply, not by the goods' condition when procured from farmers.

Section 112(2) of the CGST/UPGST Act, 2017 is invoked in a departmental GST appeal concerning a low disputed tax-and-penalty amount. The appeal challenged the first appellate authority's decision, but the grounds were considered insufficient to warrant admission for merits review. The provision is treated as supporting summary disposal where the disputed amount is low and no substantial challenge to the impugned order is identified. The matter therefore concerns the admission-stage treatment of departmental GST appeals involving limited tax and penalty disputes.

Detention and penalty for alleged reuse of e-way bills require an established contravention supported by cogent evidence. Where goods match the accompanying invoices, e-invoices and e-way bills in description, quantity, value and ownership, a vehicle's second verification on the same day does not by itself prove that the goods were previously delivered or re-transported. An undisproved repair bill and driver's explanation cannot be displaced by suspicion alone. In the absence of independent evidence of e-way bill reuse or intent to evade tax, detention and penalty proceedings are unsustainable, and the deposited amount is refundable in accordance with law.

Detention and penalty for alleged e-way bill reuse require cogent evidence of a completed earlier transport, delivery of the same goods, and intention to evade tax. Where goods are accompanied by a valid invoice, e-invoice and e-way bill, and no discrepancy exists in their description, quantity, value or ownership, an inference drawn merely from prior e-way bill verification and a later vehicle location is insufficient. Suspicion and presumptions cannot establish reuse of an e-way bill, GST contravention or tax-evasion intent; detention and penalty proceedings are therefore unsustainable.

A petition concerning a show-cause notice was disposed of with liberty to submit a reply and supporting documents. The competent authority must thereafter proceed in accordance with law after affording a reasonable opportunity to the petitioner.

Regular bail was granted in allegations of fraudulent availment and passing of input tax credit. Although further investigation into the alleged larger conspiracy remained pending, the complaint had already been filed. Continued custody, parity with a co-accused who had obtained bail, and the likelihood of a lengthy trial supported release. Bail was made subject to furnishing a personal bond and surety.

Principles of natural justice require an effective opportunity to respond to a show-cause notice before adjudication. Uploading the notice solely under the portal's "Additional Notice and Orders" tab, without separate intimation, prevented a response and hearing and breached that requirement. The limitation-based appellate rejection, underlying adjudication order, and consequential bank attachment were quashed. Fresh adjudication on the appeal grounds was directed after affording a hearing.