Residual penalty under the Customs Act requires identification of a specific statutory provision contravened where no express penalty is otherwise prescribed. A classification dispute alone does not establish a contravention by a customs broker for this purpose. Because the adjudicating authority did not identify any provision breached by the broker, and that omission was accepted, the residual penalty was unsustainable and was set aside.

National Litigation Policy monetary limits restrict Revenue appeals in customs matters where the revenue involved is below the prescribed threshold. The Tribunal dismissed the Revenue's appeal on that basis. No substantial question of law arose from that dismissal, so the connected customs appeal was also dismissed. The stated effect is to prevent continued litigation below the threshold where no legal issue warrants review.

Cash deposits during demonetisation may be satisfactorily explained by documented prior bank withdrawals and loans where the Revenue does not dispute the withdrawals or establish that the cash was used elsewhere. Mere passage of time between withdrawal and redeposit, or the obtaining of a later loan, does not by itself show that the withdrawn cash was unavailable. Treating deposits as unexplained money requires material disproving the stated source rather than presumptions about the cash's utilisation. On the stated facts, the explanation supported by prior withdrawals was sufficient, making an addition for unexplained money unsustainable.

Loss arising from transfer of non-performing assets to an asset reconstruction company crystallises when the loan portfolio is transferred for cash and security receipts and the loan accounts are closed. RBI norms require derecognition of transferred financial assets and write-off of any shortfall against net book value. Where previously deducted bad-debt provisions have already been reversed in tax computation, allowing the transfer loss does not create a double deduction. The loss is characterised as a revenue trading loss incidental to banking business, rather than a contingent or notional loss, and is allowable as a business loss under Section 28 of the Income-tax Act, 1961.

Exempt agricultural income requires authentic corroborative material showing that agricultural operations were actually carried out within the scope of the Income-tax Act. Mere ownership of agricultural land does not establish that agricultural income was generated. Where no supporting evidence is produced, the claimed agricultural income may be treated as income from other sources. A materially identical claim rejected for an earlier assessment year may not warrant a different treatment when the facts remain unchanged and no justification for departure exists.

Interest on fixed deposits maintained to secure release of retention or security money forms part of eligible-business profits for deduction under section 80IA(4). An additional deduction resulting from depreciation reallocation requires verification of the computation's factual and legal correctness before consequential relief is allowed. Section 14A read with Rule 8D does not permit expenditure disallowance where no exempt income arises in the relevant year; the Finance Act 2022 Explanation operates prospectively from 1 April 2022. Purchases supported by invoices, banking records, supplier tax returns, delivery and inventory documents cannot be characterised as bogus without evidence that payment returned in cash.

Penalty for concealment or furnishing inaccurate particulars under Section 271(1)(c) does not arise solely because a deduction for provision for bad and doubtful debts is disallowed. Liability requires a finding that income was concealed or that particulars furnished were false or erroneous. Where the claim concerns eligibility of rural branches and is made bona fide, disallowance alone does not establish either statutory condition. The penalty is therefore not leviable merely on account of the rejected deduction claim.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the interests of revenue. Where a limited-scrutiny assessment had called for and examined evidence on cash deposits, an allegation of inadequate enquiry or brief reasoning could not justify revision without identifying a specific error in the assessment findings or evidence. Directions to examine agricultural income exceeded the limited-scrutiny issue. The revision and consequential assessment were therefore unsustainable and quashed.

Audited books and remand material identifying balances as trade creditors, without identified defects, did not support treating the entire amount as unsecured loans; only a limited estimated addition was retained. Personal use of a motor car justified a proportionate, rather than total, depreciation disallowance. An electricity bill in the landlord's name did not justify a full ad hoc disallowance of trading-business administrative expenses. Supporting material for groundnut kharajat expenses made the earlier full disallowance excessive, although a limited estimate was retained.

Revision under Section 263 remains available for an assessment approved under Section 153D; such approval does not exclude revisionary jurisdiction. Absence of a Document Identification Number on the approval did not invalidate revision proceedings in light of the Supreme Court's interim stay in the relied-upon authority. Lack of inquiry into substantial bank cash deposits rendered the original assessment erroneous and prejudicial to Revenue, permitting revision. However, once unrebutted audited accounts, GST returns, cash records, sales documents, bank records, debtor ledgers and cash-flow details explained the deposits, a fresh assessment could not be directed without identifying deficiencies or adverse material.

Condonation of delay requires a cogent, satisfactory explanation showing sufficient cause and diligent conduct. Failure to regularly check emails carrying assessment intimations was unsupported and inconsistent with regular online return filing in subsequent years. Neither the assessee nor its consultant verified the assessment status for over eight years, constituting gross negligence rather than circumstances beyond its control. The 3018-day delay in filing the appeal before the Commissioner (Appeals) was therefore not condoned, and refusal of condonation was sustained.

Eligibility for staff and labour bonus deductions under Section 43B depends on verifying whether payment occurred within the statutory time permitted, including payment before the return-filing due date where applicable. Provident fund liabilities require separate verification of the actual deposit dates in the Government account before applying the governing legal rule. Both deductions therefore turn on factual confirmation of payment or deposit dates against the relevant statutory deadlines; neither claim can be conclusively determined without that verification.

Exemption under Section 10(26) is not automatic on the basis of Scheduled Tribe status alone. The claimant must furnish material establishing fulfilment of the statutory conditions and satisfactorily explain cash deposits. Non-participation in assessment proceedings and failure to provide reconciliation or source evidence prevent acceptance of the exemption claim on the available record. Where Scheduled Tribe status is undisputed and eligibility remains possible, the claim and the source of cash deposits require fresh determination after an adequate opportunity to submit supporting evidence.

Effective service of hearing notices is integral to reasonable opportunity and natural justice in appellate proceedings. Ex parte quantum orders passed after remand were unsustainable where later notices were sent to email addresses not belonging to the assessee or stated in its appeal memoranda, particularly when adjournments during the Covid-19 period had been acknowledged and substantial material required verification. The quantum assessments were remanded for fresh merits adjudication after a proper hearing. Connected penalty proceedings, arising from the same search-related documents and affected by the same deficient notice service, were also remanded on identical terms. The assessee must participate diligently without unnecessary adjournments.

Exemption under section 10(46) requires the claiming body or authority to be notified by the Central Government in the Official Gazette under section 10(46)(c). A pending application for notification does not satisfy this mandatory condition for the relevant assessment year. Pending writ proceedings concerning the requested relief likewise do not replace or suspend the notification requirement. Consequently, exemption under section 10(46) is unavailable until the requisite Central Government notification has been issued.

Functional comparability under the Transactional Net Margin Method requires similarity in functions, products and economic circumstances; a government-supported copper producer is unsuitable for comparison with a steel-wire and rod manufacturer. Profit level indicator margins should be recomputed from annual-report figures. Interest on a subordinated loan to a Thai associated enterprise is prescribed at 9%, while corporate guarantee commission is benchmarked at 0.5%. For captive power, market value for the Section 80-IA deduction is the electricity board's tariff charged to industrial consumers, not its purchase price. Further disallowances of miscellaneous and foreign travel expenses are impermissible where prior disallowances already exceed the proposed adjustments, as they create double disallowance.

Reassessment under section 147 cannot sustain an addition for income unrelated to the recorded reasons when no assessment is made of the income that formed the basis for reopening. The recorded reasons concerned alleged cash receipt and capital gains from one property sale, whereas the addition arose from the difference between stamp-duty value and consideration for a separate property transaction. Without an addition on the recorded issue, or fresh recorded reasons and notice covering the separate transaction, the unrelated addition lacked statutory basis and was deleted.

Delayed trade receivables from associated enterprises remain international transactions subject to transfer-pricing review after a reasonable credit period, even where no interest is charged to either associated or non-associated enterprises. A 60-day credit period applies for benchmarking. Notional interest must be recomputed by considering interest-free associated-enterprise trade payables against receivables, including their respective outstanding periods. Foreign-currency receivables require a currency-specific benchmark, using LIBOR plus 200 basis points rather than domestic rupee deposit rates. Receivables must also be evaluated with the underlying sales transaction, including aggregation principles and any working-capital adjustment reflected in profitability.

Section 127(1) requires the competent authority, where possible, to give the assessee a reasonable hearing, record reasons for transferring jurisdiction, and communicate the transfer order and reasons. Failure to issue notice, invite objections, record reasons, or communicate them prevents an effective challenge to the transfer and creates a serious jurisdictional defect. Where jurisdiction is transferred without compliance with these mandatory safeguards, the receiving officer lacks valid authority to issue a Section 153A notice or conduct consequential search assessment proceedings under Section 143(3) read with Section 153A.

Unsecured loans supported by confirmation, bank statements, PAN details and audited lender financial statements must be assessed on their own evidence. Receipt and repayment through banking channels, together with interest paid before reassessment, substantiate the transaction's identity, creditworthiness and genuineness. Suspicion arising from an alleged accommodation-entry provider's control of the lender does not, by itself, justify treating the loan as unexplained cash credit. Where the loan is satisfactorily established, the related interest disallowance cannot be sustained.