Interest received from loans advanced to companies is taxable under Income from Other Sources where no agency or management contract, or termination or modification of such contract, supports assessment under Section 28(ii)(a). Although lending may be viewed as an adventure in the nature of trade, the stated basis of assessment cannot be replaced at the appellate stage with a different general basis under Section 28. Interest paid on borrowed funds used to make the interest-bearing advances is deductible under Section 57(iii) when a reasonable and proximate nexus with the income earned is established. The Explanation to Section 37(1) does not govern expenditure once the related income is assessed under Income from Other Sources.

Stamp-duty payment is not unexplained investment under Section 69 where the assessee substantiates its source through funds received from a father-in-law. The father-in-law's income-tax return established identity and financial capacity, while the supporting material on creditworthiness was neither disputed nor independently discredited. The explanation for the payment source was therefore sufficiently supported, precluding an addition as unexplained investment.

Properties devolving on a beneficiary upon dissolution of a family trust fall within succession, inheritance or devolution under Section 49(1)(iii)(a). Where acquisition cost is determined by reference to the previous owner, the previous owner's holding period must be included in determining whether the asset is long-term under Explanation 1(b) to Section 2(42A). The same deeming framework applies to indexed cost under Section 48, permitting indexation from the year in which the previous owner first held the property. Accordingly, sale gains are treated as long-term capital gains rather than short-term gains.

Depreciation on goodwill arising from amalgamation, and on brands and trade names transferred through demerger, was treated as allowable where consistent prior treatment applied and no distinguishing facts existed. For captive-power inter-unit electricity transfers, market value was the price paid by the recipient manufacturing unit for open-market electricity, rather than the generator-to-distributor tariff. Steam transferred from an eligible captive-power unit to a non-eligible unit could not be assigned nil value merely because it was a by-product; arm's length valuation may rely on reliable external market comparables rather than internal cost. The disallowances and transfer-pricing adjustments were deleted.

Unexplained cash credits described as advances against future sales require independent evidence of the customers' identity, creditworthiness and the genuineness of the transactions; self-maintained ledgers and matching subsequent sales entries do not establish the original credits. The addition was therefore sustained. Where no binding jurisdictional or Supreme Court authority resolves divergent interpretations of a taxing amendment, the interpretation favourable to the assessee applies. The enhanced tax rate under amended section 115BBE was prospective from assessment year 2018-19 and did not apply to assessment year 2017-18; the sustained addition was taxable at the pre-amendment rate.

Reassessment notices issued beyond four years under the pre-2021 regime could be sanctioned by any authority specified in Section 151(1), including the Principal Commissioner; exclusive approval by the Principal Chief Commissioner was not required. Valid jurisdiction nevertheless required recorded reasons showing a bona fide belief of escaped income and meaningful statutory satisfaction. Incorrect PAN details, the false assertion that no return was filed, absence of a link between reported transactions and escaped taxable income, failure to quantify escaped income at the statutory threshold, and an approval proposal repeating those defects demonstrated invalid jurisdiction. The reassessment notice, consequential reassessment and additions were therefore quashed.

Agricultural-land exclusion from capital gains depends on the land's recorded status, contractual description, actual use and intended use at transfer. Land described in registered instruments as industrial-purpose, recorded as uncultivated and acquired for non-agricultural use may be treated as a capital asset rather than excluded agricultural land. Reinvestment relief under Section 54B requires fulfilment of the prescribed agricultural-use conditions, including use of the transferred land for agriculture during the relevant preceding period. An unchallenged revision order cannot be collaterally contested in proceedings concerning the consequential assessment.

Deduction of cost of funds and related expenditure claimed by a co-operative society was remitted for fresh adjudication after the disallowance was considered against applicable precedent on deposits. The intimation, assessment and penalty orders were quashed because the taxpayer had not responded to notices due to the stated failure of its former tax practitioner. The taxpayer may file objections and respond to the notice issued under the Income-tax Act, while all merits-based contentions remain open for reconsideration.

Preliminary reassessment measures under Sections 148A and 148 are ordinarily not subject to writ challenge before reassessment is completed where the statutory process permits the assessee to raise factual and jurisdictional objections before the Assessing Officer and appellate authorities. Notices, preliminary orders and reassessment notices do not themselves determine tax liability or preclude objections on the applicability of Section 152(3) or approval under Section 151. Threshold intervention under Article 226 is confined to exceptional situations involving total lack of jurisdiction or a patent breach of a mandatory precondition; objections requiring examination of underlying information or search material should be pursued through the reassessment mechanism.

Consequential refund interest required computation after appellate effect orders where the claimed period exceeded the prescribed time for giving effect. The Assessing Officer was required to compute interest under Section 244A(1A), verify whether TDS credit for Assessment Year 2014-15 matched Form 26AS, and grant consequential refund interest under Section 244A(1) if a short credit or short grant was established. Further directions remained pending after verification and computation.

Reassessment notices alleging undisclosed interest on capital and partner remuneration were invalid where the partnership deeds made such payments contingent on mutual agreement rather than mandatory. The amended deed expressly provided that no interest on partners' capital was payable, and no material established actual receipt of interest or remuneration. Treating amounts as necessarily payable merely because earlier deed clauses contemplated them was erroneous. The reopening basis, also found legally unsustainable in the firm's assessments, lacked jurisdiction; the reassessment notices were quashed.

Reassessment based on an alleged incorrect loss computation after a share split is impermissible where the original scrutiny assessment examined the same share transactions, valuation, purchase and sale details, capital gain or loss, and supporting records. Complete transaction, allotment and banking evidence had been furnished, and the reopening reasons identified neither fresh tangible material nor any failure to disclose material facts. Revisiting the tax effect of a 1:10 share split on previously scrutinised transactions constitutes a change of opinion. Reassessment requires fresh tangible material indicating escaped income and, where applicable, a failure of full and true disclosure.

Actuarial-deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions because they remedy funding shortfalls between fund assets and actuarial liabilities. Rule 87 and Rule 103 annual ceilings do not restrict such deficit funding, and section 36(1)(v) permits contributions to an approved gratuity fund without an additional percentage ceiling while approval remains valid. Employee PF/ESI contributions cannot be disallowed under section 36(1)(va) unless the governing legal regime prescribes a due date; a tax-audit software entry or an unrelated provident-fund scheme deadline does not create one.

Refunds quantified following assessment of tax deducted at source obligations or pursuant to an appellate order constitute vested and crystallised entitlements carrying applicable statutory interest. Form 26B, together with the processing framework for TDS statements, applies to CPC-stage processing and adjustment before assessment and does not govern such quantified refunds. Outstanding demands, including those concerning associated TANs, do not independently permit non-payment or adjustment. A refund may be withheld or set off only under a lawfully passed order for adjustment of refunds. The taxpayer is therefore entitled to payment of the quantified refund with applicable interest unless a valid adjustment order exists.

GST exemption for fresh Psyllium (Isabgol) seeds depends on proving that the seeds retain their fresh condition at the time of supply. Seeds stored in dry, ventilated godowns, without evidence of the period from harvest through procurement to supply, are treated as dried rather than fresh; labelling as dried is unnecessary. Such supplies fall under the specific rate entry for dried goods under heading 1211 and attract GST at 5%, rather than the exemption for fresh seeds. The alternative exemption for goods of seed quality is unavailable where the seeds are classified as dried taxable goods.

Penalty for transporting goods without an e-way bill at interception is not sustainable where the e-way bill is generated shortly thereafter, the transaction is genuine and fully documented, and no intent to evade tax is established. Section 129(3) was invoked for non-generation of the e-way bill under Rule 138(1), but invoices, challans, ledgers, bank records, and traceable vehicle and goods identifiers substantiated the supplies. In the absence of discrepancies in quantity, value or classification, or evidence of suppression, undervaluation, fake documentation, unaccounted goods or tax evasion, the lapse was treated as bona fide and procedural. The penalty orders were liable to be set aside.

Transport of taxable goods requires generation of an e-way bill before movement begins where the prescribed value threshold is met. Subsequent production of an e-way bill does not remedy its admitted absence at interception. The e-way bill functions as an electronic mechanism for monitoring goods in transit, and failure to generate it before transportation may support an inference of intent to evade tax, particularly in the stated circumstances of short cross-border movement of iron scrap. Detention and penalty provisions may therefore be invoked for transport without a pre-generated e-way bill.

Inter-Commissionerate transfer of Executive Assistants is impermissible where the applicable recruitment rules and transfer policy do not permit absorption in the receiving Commissionerate. The Executive Assistant Recruitment Rules, 2015 maintained separate cadres for each Cadre Controlling Authority unless the Board directed otherwise. As no distinct rule authorised transfer of Executive Assistants between Commissionerates, officers transferred in contravention of this cadre structure could be treated as deemed loan cases and repatriated to their parent zones.

Functional availability of the GST Tribunal provides the statutory appellate remedy against the impugned orders. The petitioner may file an appeal before the Tribunal within 30 days, and the amount deposited under the interim order will be adjusted towards the required pre-deposit. The appeal is to be considered on merits.

Delayed or non-deposit of GST/TDS deducted for Gram Sabha works falls within the comprehensive mechanism of the Uttar Pradesh GST Act, including interest, penalties, prosecution and compounding. General penal prosecution is available only where allegations independently establish a distinct criminal offence, such as dishonest misappropriation, forgery, cheating, siphoning of funds or wrongful gain. Further, substantive offences under the Bharatiya Nyaya Sanhita, 2023 cannot apply retrospectively to conduct occurring before its commencement; later procedural law may govern investigation, but not criminal liability. Criminal proceedings based solely on a tax default and a subsequently enacted substantive penal provision are legally unsustainable.