Search-seized material relating to a person other than the searched person must be addressed through the special assessment procedure under Sections 153C and 153A, rather than regular reassessment under Sections 147 and 148. Sections 153A to 153D have overriding operation where the seized material belongs to or relates to that other person and is relevant to determining total income. Reassessment notices based on conclusions drawn from such material are therefore invalid; any action must proceed under Section 153C.

Approval under section 80G(5) requires satisfaction regarding genuine activities and compliance with statutory conditions. An object in the trust deed permitting receipt or application of funds outside India raised a compliance concern. Where the trust had initiated amendment of its objects to restrict operations to India, reconsideration after filing the amended trust deed was warranted. The rejection of approval was set aside, and the application was restored for fresh adjudication upon submission of amended objects or the amended trust deed.

Under the mercantile system, a provision for audit fees is deductible only when audit services have been rendered and the corresponding liability has accrued and crystallised during the relevant year. A statutory obligation to obtain an audit does not itself create an enforceable liability before the audit is undertaken; an uncrystallised provision remains contingent. Audit fees relating to an earlier period may be claimed in the payment year as prior-period expenditure after recasting the accounts. Delayed employees' EPF contributions require verification of the actual delayed amount, and any disallowance must be restricted to the amount so verified.

Reassessment initiated beyond four years from the end of the assessment year requires failure to disclose fully and truly all material facts where the original assessment was completed after scrutiny. Depreciation-related material, including the completion certificate and employee statements on whether the building, plant and machinery were put to use, had been disclosed, queried and considered in the original assessment. Reopening on the same material constituted a change of opinion rather than a failure of disclosure. The reassessment was therefore invalid, and the consequential orders were quashed.

Revisionary jurisdiction under Section 263 cannot be used to direct reassessment of share premium valuation under Section 56(2)(viib) where limited scrutiny was confined to verifying the genuineness and disclosed source of share application money. Verification of identity, genuineness and source is distinct from determining whether share premium exceeds fair market value. An Assessing Officer cannot expand a limited-scrutiny enquiry beyond its specified reasons unless it is converted into complete scrutiny. Without such conversion, the assessment was not erroneous or prejudicial to Revenue on the share-premium valuation issue, and the revisionary order was quashed.

For assessment years preceding the amended reassessment regime, the first proviso to Section 149(1) preserves the former six-year limitation for issuing a Section 148 notice. That separate restriction is not extended by later provisos. Where the six-year period expired on 31 March 2022, a notice issued on 4 April 2022 was time-barred. The resulting reassessment and consequential addition were legally unsustainable and required deletion.

Interest and dividend income earned by a co-operative society from investments with another co-operative society qualifies for deduction under Section 80P(2)(d). A co-operative bank remains a co-operative society for this purpose. The exclusion applicable to co-operative banks under Section 80P(4) restricts a bank's own claim for deduction and does not prevent another co-operative society from claiming deduction on interest received from deposits with a co-operative bank. Accordingly, interest on such deposits is deductible under Section 80P(2)(d).

For cash deposits made during demonetisation and examined under Section 69A, cash-flow statements and income-tax returns supported the availability of rental income and cash after 1 April 2011. The opening cash balance on that date remained unsupported by documentary evidence, and the cash-flow statement did not sufficiently provide for household drawings and personal or incidental expenditure. Estimated personal expenditure of Rs. 2,50,000 was therefore treated as unexplained, while Rs. 11,00,000 of the disputed deposit was accepted as explained cash availability.

Additional documentary evidence supporting a Section 54F exemption claim may be admitted under Rule 29 where it is necessary for a just decision, substantial cause exists, or the taxpayer lacked adequate earlier opportunity to produce it. A purchase agreement and bank statements material to proving investment in a new residential property satisfied these conditions, particularly as the explanation for earlier non-production was accepted and the Revenue produced no material to challenge admission. The evidence may be considered by the income-tax authority under Rule 30, requiring fresh determination of the exemption claim after that consideration.

Foreign tax credit for Australian taxes paid on income also taxed in India remains available despite delayed filing and verification of Form 67. Section 90 and Article 15 of the India-Australia tax treaty protect against double taxation, while Rule 128(9) prescribes the filing timeline without providing that delay forfeits credit. Form 67 filing is therefore procedural and directory where foreign tax was paid, corresponding income was taxed in India, and delay arose from technical verification difficulties and travel restrictions. Denial solely for late filing would defeat the substantive treaty entitlement and cause double taxation.

Reassessment jurisdiction is confined to the income-escaping information recorded as the basis for reopening. Where recorded reasons concern cash withdrawals and deposits, but no addition is made on those matters, additions for estimated net profit and alleged unaccounted purchases cannot independently sustain the reassessment. Failure of the recorded basis invalidates the reassessment and requires it to be set aside.

Transportation-expense disallowance is examined against an earlier appellate premise that the assessee came into existence only on 17 April 2017 and therefore could not have undertaken work or entered into an arrangement beforehand. The joint-venture agreement referred to a memorandum of understanding dated 28 November 2016, departmental PAN records showed that date as the incorporation date, and work orders pre-dated 17 April 2017. These materials identify an apparent factual error relevant to reconsideration of the transportation-expense ground.

Repayments of advances previously made through banking channels do not constitute unexplained cash credits where bank records establish the original advances and their repayment by account-payee cheques. Counterparties' bank statements, income-tax returns and balance sheets may substantiate transaction genuineness and creditworthiness. Where the source of the original advances was not disputed in the earlier assessment year, the returned amounts are repayments of existing advances rather than fresh loans and cannot be assessed under Section 68 of the Income-tax Act, 1961.

Reverse-charge GST coverage is extended to supplies of specified essential oils, other than citrus-fruit oils, where an unregistered person supplies them to a registered person. The category covers peppermint oil and other mint oils, including spearmint, water mint, horsemint and bergamot oil. Entry 3A is inserted into the existing reverse-charge schedule, identifying the registered recipient for reverse-charge purposes.

Mandatory Bureau of Indian Standards (BIS) certification requirements for equipment and components used by high-technology manufacturers may be addressed through a proposed exemption framework. Possible exemptions may be structured at the company, industry, product, project or bulk level to support timely availability of imported equipment, goods and services for manufacturing operations. The approach is directed at high-technology industries generally, particularly semiconductor and artificial intelligence sectors, while addressing delays associated with mandatory certification and complex procedures for specialised imported parts and equipment.

Corporate social responsibility should prioritise measurable community outcomes rather than expenditure alone. Effective CSR depends on community-responsive design, capable implementing agencies, rigorous monitoring, social audits, and transparent use of technology and data. Public sector enterprises may use thematic priorities, convergence with government programmes, and institutional collaboration to replace isolated interventions with strategic CSR. CSR capacity building encompasses legal and regulatory frameworks, governance, project planning, impact assessment, reporting, ESG and the Social Stock Exchange.

Regional Rural Banks achieved prescribed priority-sector lending targets and sub-targets, expanded financial inclusion through new Pradhan Mantri Jan Dhan Yojana accounts, and recorded improvement in profitability, asset quality, and credit-deposit ratio. Digital banking adoption is to be accelerated to improve operational efficiency, customer experience, and banking access in rural and remote areas. Sponsor Banks are expected to strengthen information-technology infrastructure and support increased area-specific credit flows and innovative lending.

The State tax exemption schedule substitutes the entry for tariff heading 1209 to cover seeds, fruit and spores of a kind used for sowing. Seeds intended for any use other than sowing are expressly excluded, restricting exemption treatment to products used for sowing. The substituted entry takes effect from 1 October 2021.

GST registration applications require biometric Aadhaar authentication and photograph capture where Aadhaar authentication is chosen, or biometric information, photograph, notified KYC documents and original-document verification where it is not chosen. Registration may be suspended where return comparisons or related analyses reveal significant discrepancies indicating contraventions that may lead to cancellation, with FORM GST REG-31 requiring an explanation within thirty days. Input tax credit restrictions are tightened, and Rule 86B limits electronic credit ledger use for output-tax payment, subject to specified exceptions and possible removal after verification.

Jurisdictional validity of assessments and reassessments issued in the name of an amalgamated, non-existing company requires determination of whether merger information was furnished to the Assessing Officer before notice issuance or during assessment proceedings. This threshold issue governs consideration of the warranty-provision disallowance. Additional evidence on warranty expenditure requires factual examination. The matters were remitted to the Commissioner (Appeals) for fresh adjudication after opportunity to both sides.