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.

Detention of goods for alleged reuse of an e-way bill requires cogent evidence that the same goods had completed an earlier journey and that the e-way bill was reused. Where goods are accompanied by an invoice, e-invoice and e-way bill, with no discrepancy in description, quantity, value or ownership, an earlier vehicle verification or location alone cannot establish re-transportation. Contravention of GST law and intention to evade tax cannot be presumed from suspicion; the department must prove both by independent evidence. On these facts, the detention and penalty proceedings were set aside, and refund of the deposited amount was directed in accordance with law.

Alleged reuse of an e-way bill cannot justify detention and penalty where the goods are supported by an invoice, e-invoice and e-way bill without discrepancies in description, quantity, value or ownership. Re-transportation must be established by independent, cogent evidence that an earlier journey was completed or the goods were delivered; an inference from prior e-way bill verification alone is insufficient. Intention to evade tax cannot be presumed from suspicion, and the alleged falsity of a vehicle-repair bill must also be proved. The detention and penalty orders were set aside, and refund of the deposited amount was directed in accordance with law.

Psyllium seeds fall under tariff sub-heading 1211 90 13 within Heading 1211. GST exemption for fresh or chilled seeds depends on the goods' condition when supplied, not on processes before procurement from farmers. Storage in dry ventilated godowns constitutes drying, and absent evidence that the seeds remained fresh from harvest through onward supply, they cannot be treated as fresh or chilled. The supplies therefore fall under the rate entry for dried goods and are taxable at 5%. Exemption claimed for goods of seed quality is also unavailable on that classification.

Tax-residency relief for Indian seafarers unable to remain outside India during the COVID-19 pandemic was sought through quashing CBDT Circular No. 11 of 2020 and adoption of a compassionate tax policy. The proposed policy would grant at least sixty days' exemption to seafarers who spent more than 182 days in India during a financial year. Representations were directed to receive sympathetic consideration, with an appropriate decision requested within four weeks, without examination of merits.

Section 260A confines High Court interference with Tribunal findings on rejection of books, income estimation and fee refunds to cases of perversity, lack of evidentiary support or legal error. Where seized material, account books and submissions require factual examination, alternative computations do not themselves create a substantial question of law. Once books are rejected, income and allowable fee refunds may be determined by estimation. The Tribunal may examine the basis and extent of fee-refund relief when the Revenue challenges that relief and the assessee files a cross-objection concerning the sustained addition; this remains within its appellate jurisdiction.

Fees paid to the Registrar of Companies for increasing share capital through shares issued to a holding company qualify for amortisation as preliminary expenditure. The provision covers expenditure incurred in connection with the issue of shares; it is not confined to expenses relating to a public subscription. The enumerated expenses are descriptive, and the comma after "issue" prevents a restrictive reading that would exclude Registrar fees. Accordingly, disallowance of the claimed amortisation was unsustainable, and amortisation of the share-capital issue fees was allowed.

Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.

Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.

Revision of an assessment for lack of inquiry requires an erroneous and prejudicial order, not merely a different view of matters examined during scrutiny. Where the Assessing Officer made inquiries into depreciation on fixed assets, commission paid to a non-resident, and deductions for employing new workmen, and applied mind to the responses, revision was not sustainable. The Principal Commissioner had identified neither a flaw in the assessee's replies nor a specific defect in the prescribed audit report. The revision order was quashed, and the tax appeal was dismissed because the Tribunal's findings disclosed no legal infirmity.

Excess self-assessment tax refunded after appellate relief attracts interest as a statutory, non-discretionary consequence where tax ultimately chargeable is lower than tax paid. Refund entitlement arises when tax deducted at source, advance tax, self-assessment tax, or regular-assessment tax exceeds the final annual tax liability following appeal or other proceedings. Where prescribed computation categories do not govern, interest on excess tax runs from the payment date. Unpaid interest on the resulting refund must be determined and paid for the relevant period, including up to the point at which interest had already been granted.

Advance-tax payment otherwise payable is a precondition to admission of an income-tax appeal where no return of income has been filed, unless exemption is sought and granted for good and sufficient reason. A claimed absence of taxable income and corresponding advance-tax liability requires examination where neither the taxpayer nor the Assessing Officer has computed the liability; it cannot be rejected summarily merely because no exemption application was filed. Dismissal for non-compliance in those circumstances requires fresh consideration with an opportunity to explain the claim. Penalty appeals concerning under-reporting of income and audit default, where based on the same admission objection, follow the same treatment.

Genuine share transactions supported by banking records and transfer documents cannot be disregarded merely because they generate a tax loss. The discussion identifies that no adverse material established an artificial or pre-conceived arrangement, and the sale price exceeded the price at which another related purchaser had acquired the shares. On these facts, the short-term capital loss from sale of unlisted shares to a spouse was not treated as a colourable device, and its disallowance was deleted.

Transfer-pricing provisions apply to transactions between associated enterprises and cannot be used to benchmark royalty paid to an independent foreign licensor unless material establishes a deemed associated-enterprise relationship through a prior agreement or specific arrangement. Where the licensor was not disclosed as related and no such material existed, the royalty transaction remained independent. A bona fide royalty rate agreed under a licence agreement could not be disallowed under section 37 merely because it was considered excessive by reference to external royalty comparables. The royalty disallowance was deleted; remaining grounds were left open.

Under TNMM, comparables for an assessee providing ITeS support services to its associated enterprise must be functionally similar and capable of reliable comparison. Tata Elxsi was unsuitable because its design and engineering, digital-content, R&D and software-development activities involved substantial intangibles. TTEC India Customer Solutions was unsuitable because its BPO, technology and AI-enhanced offerings differed from the tested ITeS support services. CHEERS was unsuitable because its mixed ITeS and other operations lacked segmental information. All three were excluded from the final comparable set; the issue of the assessee's unaudited segmental information remained open.

Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed.

Rectification of DRP directions that changed AMP benchmarking from the earlier approach to intensity-adjusted TNMM, on the CIT(DR)'s application, was unsustainable; the rectified directions and consequential assessment order were set aside. Original DRP directions requiring deletion of a protective AMP adjustment bound the assessment proceedings, so the protective adjustment based on the Bright Line Test was also set aside. AMP transfer-pricing adjustments derived through both the Bright Line Test and intensity-adjusted TNMM were unsustainable for the relevant year and corresponding subsequent years. The impugned assessment orders were set aside, while academic, consequential and unpressed grounds remained open or were not pressed.

Transfer-pricing benchmarking for administrative and marketing support services requires functional similarity and adequate segmental data. Engineering consultancy, construction-related activities, trading and mixed sales-service operations, commission agency and technical services are unsuitable comparables; a different financial year alone does not require exclusion where an appropriate adjustment is possible. For IT-enabled services, outsourcing businesses without segmental information and knowledge-process outsourcing providers are functionally dissimilar. Proposed comparables needing review of segmental or financial data, including those affected by a service-income filter, require verification and fresh computation. Claimed comparable-margin corrections and risk adjustments depend on substantiation, factual reconciliation and consequential examination.

Deduction for expenditure allegedly disallowed in an earlier year for tax-deduction-at-source default requires evidence that the earlier disallowance was made under the relevant provision; a revised computation cannot support the balance annuity deduction without that factual foundation. A return-processing adjustment must be challenged through the separate statutory appeal already filed where no fresh addition is made in the assessment order. Exemption for an entity under section 10(46) requires the prescribed notification; a pending writ petition, absent a stay or specific direction, does not suspend proceedings or establish exemption eligibility. The deduction and exemption claims were rejected, and all appeals were dismissed.

Goodwill write-off already added back in computing taxable income should not be added again in assessment; an ambiguous rectification that potentially disallows goodwill beyond withdrawal of consequential depreciation cannot prejudice the assessee. The further goodwill disallowance was deleted, while the depreciation disallowance was sustained on the assessee's concession. A claim for set-off of brought-forward business losses requires verification of its quantum and eligibility from earlier-year records where it has not been adjudicated. That claim was remitted to the AO for verification and lawful set-off after reasonable opportunity. The appeal was partly allowed for statistical purposes.