Actuarial deficit contributions made to an approved superannuation fund to align fund assets with actuarial liabilities are distinguished from ordinary annual or initial contributions. Because their purpose is to remedy an actuarial shortfall, they are not subject to the Rule 87 ceiling on annual contributions, preserving the fund's solvency. Similarly, contributions bridging actuarial liability and available assets in an approved gratuity fund are not ordinary annual contributions subject to the Rule 103 ceiling. Unless approval is formally withdrawn, the assessing authority must accept the fund's approved status and cannot, during assessment, question compliance with the Rules to restrict the deduction.

Actuarial-deficit contributions to an approved superannuation fund are distinguished from ordinary annual and initial contributions by their purpose. Ad hoc payments required to align fund assets with actuarial liabilities and cure accumulated funding deficiencies fall outside the Rule 87 ceiling for ordinary annual contributions; applying that ceiling could undermine the fund's solvency and the deduction framework for approved funds. A reasoned appellate determination based on jurisdictional precedent is not perverse or arbitrary merely because the revenue disputes its application. The disallowance of actuarially determined deficit contributions was deleted, and the revenue's challenge failed.

Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.

The doctrine of merger applies where the Appellate Tribunal has passed a final order in an appeal: prior interlocutory orders, including a recall order, merge into the final appellate order and cease to have independent existence. A writ petition challenging the recall order therefore cannot survive once the final order is challenged through the available statutory tax appeal. The challenge to the final order must be pursued in that statutory appellate remedy, and the writ petition was dismissed.

Extended limitation for sale of attached immovable property operates retrospectively as a procedural amendment only where the original limitation had not expired when the amendment took effect; it cannot revive already time-barred recovery claims. The seven-year period therefore applied to later assessment years whose unamended limitation remained alive, while sale proceedings for earlier time-barred years were barred. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial, allowing exclusion of the Supreme Court-prescribed COVID-19 limitation period and court-ordered stay periods. Where no appeal is filed, limitation under Rule 68B begins after expiry of the notice-of-demand period, when the assessment becomes final for recovery purposes.

Deduction of interest income from co-operative banks under section 80P(2)(d) was allowed to a co-operative housing society. The Tribunal followed its decisions in the society's own earlier assessment years because no distinguishing facts for the relevant year were identified. The Assessing Officer was directed to grant the claimed deduction on interest earned from co-operative banks.

For reassessment notices issued more than three years after the end of the relevant assessment year, prior approval from the higher specified authority under section 151(ii) is a jurisdictional precondition. Approval from the Principal Commissioner under section 151(i) is insufficient where section 151(ii) applies. Applying this requirement to assessment year 2018-19, the section 148 notice and reassessment under sections 147 and 144B were void ab initio because the required approval was not obtained. The appeal was allowed after condoning delay, and the reassessment was quashed.

Charitable purpose is not defeated where sponsorship receipts from a women's marathon have a real and proximate nexus with objects of women's health, fitness, awareness and empowerment. The proviso to section 2(15) requires proof that the recipient's activity intrinsically operates as trade, commerce or business; sponsors' advertising treatment, receipt magnitude or surplus alone is insufficient. The 20% receipts formulation did not apply for the relevant assessment year, and exceeding the applicable monetary threshold could not replace that proof. Consequently, section 13(8) could not deny exemption under sections 11 and 12. Form No. 10B furnished during assessment cured an erroneous original exemption form where audit was completed before return filing and eligibility was examined on merits; the lapse was procedural.

Assessment issued in the name of an amalgamated entity that has ceased to exist is an incurable jurisdictional defect and void from inception. Where the Assessing Officer knew of the amalgamation, the successor entity's participation cannot validate the assessment or cure it as a procedural irregularity under section 292B. Supreme Court precedent treats such assessment as a substantive illegality affecting jurisdiction. Consequently, the assessment against the erstwhile bank was quashed, and the merits of the additions were not examined.

Commission expenditure supported by the recipient's tax and GST records, TDS details and bank-payment evidence cannot be disallowed solely because the recipient does not comply with a departmental notice, absent proof that the evidence is false, the identity is fictitious or funds returned to the payer. Primary evidence of a creditor's identity, creditworthiness and transaction genuineness shifts the burden to the Revenue; unsupported cash-credit additions fail. Business expenditure for customary lorry tips and refreshments may be allowable where commercially plausible, books are not rejected and no payment is shown to be bogus, inflated or non-business, despite absence of formal vouchers.

Excess TDS becomes refundable where reassessment proceedings initiated under section 148 accept the return and determine nil taxable income. Under section 237, tax paid in excess of tax properly chargeable must be refunded; no outstanding liability remains after such assessment. The refund is consequential to the reassessment rather than a fresh claim beyond its scope. The principle applies even where reassessment proceedings are dropped or culminate without additional taxable income, and the restriction on reopening concluded matters does not bar this consequential relief. Statutory interest on the excess TDS refund follows in accordance with law.

State-law registration required for educational approval under section 10(23C)(vi) was satisfied once registration with the competent Devsthan authority had been obtained, so absence of registration could not support rejection. Compliance with mandatory State or local registration requirements remains necessary. Trustee ownership of land used for educational infrastructure, without evidence of siphoning, private appropriation, diversion of funds or pecuniary advantage, does not establish private benefit. Incidental surplus from educational activities also does not demonstrate a profit motive where retained and applied to educational infrastructure and facilities. Approval was directed because the institution operated solely for education and not for profit.

Interest earned by a co-operative housing society on fixed deposits with co-operative banks qualifies for deduction under section 80P(2)(d), provided the investment is with another co-operative society. A co-operative bank registered under applicable co-operative societies law remains a co-operative society for that purpose. Section 80P(4) restricts deductions claimed by co-operative banks themselves and does not limit the deduction available to an investing co-operative society. This interpretation is consistent with the liberal construction of beneficial provisions and Tribunal decisions applying the principle. The disallowance of the claimed deduction was deleted.

Penalty for under-reporting under section 270A was inapplicable where lease-rental disallowance for non-deduction of tax at source arose from a bona fide, debatable interpretation of GNOIDA's status as a Government body. The taxpayer had disclosed the material facts, and neither the Assessing Officer nor the Commissioner (Appeals) found the explanation to lack bona fides. Confirmation of the underlying disallowance alone did not establish under-reporting for penalty purposes. The penalty was therefore deleted, applying the principle that an unsuccessful claim does not by itself justify penalty where the explanation is bona fide and fully disclosed.

Corpus donations received by a charitable trust with a specific direction to form part of its corpus are treated as exempt capital receipts. A harmonious reading of the provisions on voluntary contributions, charitable-trust exemptions and the relevant CBDT circular supports exclusion of such receipts from taxable income. Where the trust is registered under the applicable charitable registration provisions and its income, excluding exempt corpus receipts, remains below the taxable limit, the audit requirement and filing of Form No. 10B are not attracted. Non-furnishing of Form No. 10B therefore does not defeat the exemption for qualifying corpus contributions.

Enhanced taxation of unexplained income under the amended Section 115BBE was treated as prospective, applying from Assessment Year 2018-19 rather than Assessment Year 2017-18. Where High Court decisions conflict and no binding jurisdictional High Court or Supreme Court ruling exists, the interpretation favourable to the assessee applies; tax for the earlier year is therefore computed under the unamended provision. Cash deposits used to repay a bank loan may be treated as unexplained money under Section 69A when their source lacks documentary support, but the entire deposit need not be added if reasonable cash-in-hand is available for ordinary requirements. The unexplained-money addition was consequently restricted.

Judicial review of Settlement Commission orders is limited to jurisdictional or statutory infirmity, prejudice, fraud, bias or malice and cannot operate as an appellate reassessment of the underlying adjudication. Where parties voluntarily settle proceedings arising from a show cause notice without pursuing the statutory appeal, they cannot reopen the notice's validity on limitation or reasonable-period grounds by challenging a consequential interest direction. Statutory interest remains a consequence of customs duty liability despite settlement of the duty quantum. Verification and quantification of further interest by the jurisdictional Commissioner may therefore be directed, subject to any independently maintainable challenge to the statutory computation.

Unauthorised lending of a Customs Broker licence and dongle to a G-card holder for consideration constitutes an impermissible transfer because the prohibition applies to the substance of the arrangement, not merely proprietary title. Filing a Shipping Bill in an exporter's name without that exporter's authority, while failing to verify the client's identity and functioning, independently breaches Customs Broker obligations; verification of IEC and GST particulars alone is insufficient, and knowledge of prohibited goods is unnecessary. No separate breach arose from information imparted to a client where no incorrect information was identified. Revocation, security forfeiture and penalty remained proportionate to the cumulative misconduct.

Writ jurisdiction does not ordinarily permit resolution of disputed facts concerning the presence of a Customs Broker during sampling of seized imported industrial oil. The objection to the first sample depended on a factual dispute: the importer denied the representative's presence, while the respondents and sampling report recorded it. The representative's presence during subsequent sampling was admitted. The relevant test report also indicated that the declared industrial oil failed applicable parameters, an issue addressed in an earlier decision. The challenge to seizure was therefore rejected, with no interference warranted on the disputed sampling objection.

Reliable and corroborative evidence is required to support allegations that duty-free imports under a DEEC licence were diverted and that fraudulent exports were made. Official export documentation, manufacturing confirmation, export-proceeds realisation and a criminal-court-accepted closure report were treated as material circumstances; suspicion, unreconciled gaps and uncorroborated assertions could not establish diversion. A duty demand cannot be confirmed on classification, product-description or licence-amendment grounds absent from the show cause notice. Retracted or inconsistent Customs Act statements require independent corroboration and compliance with statutory safeguards. Where the alleged fraud lacks evidentiary support, penalties for abetment or connivance lack an independent foundation. The duty demand, interest and penalties were set aside.