Medicated Toilet Soap is classified under tariff item 34011110, separate from other toilet soaps classified under tariff item 34011190. The revised GST notification adopts the Customs Tariff nomenclature and interpretative rules. The concessional Schedule I entry for toilet soap applies only to products under tariff item 34011190 and does not extend to Medicated Toilet Soap. Medicated Toilet Soap therefore falls under the residual Schedule II entry and attracts GST at 18% (9% CGST and 9% SGST).

Section 80-IE deduction remains available where an industrial undertaking is not formed by splitting up or reconstruction of an existing business and previously used plant and machinery does not exceed the statutory limit. Eligible profits cannot be recomputed through notional allocation of related-party expenses unless material establishes an arrangement, beyond close connection alone, designed to generate more than ordinary profits. Excise-duty incentives intended to promote industrial development and employment are capital receipts, excluded both from taxable income and from eligible profits for the deduction. Working-partner remuneration cannot be disallowed twice where it has already been added back in the revised return.

TDS credit deducted by an employer cannot be denied to a salaried taxpayer solely because the employer failed to deposit the tax with the Revenue. The taxpayer remains entitled to credit where tax was deducted and cannot be made to bear the deductor's default. Denial through an intimation, consequential demand and recovery from refund was set aside to the extent of the disallowed TDS credit, with restoration of the recovered amount and applicable interest.

Where an income-tax refund is due and adjustment against an outstanding demand is proposed under section 245 of the Income-tax Act, 1961, the tax department may retain only the amount proposed for adjustment or withholding. It must promptly release the balance refund, without prejudicing either party's right to challenge the legality of the outstanding demand or the proposed adjustment. The balance refund was directed to be credited within the stipulated period; failure to do so would attract interest at the rate directed by the High Court.

Limitation for penalties arising from alleged cash receipts contrary to section 269ST remains subject to differing views on when the limitation period under section 275(1)(c) begins. Under either approach, penalty proceedings under section 271DA were time-barred because the assessment orders were passed in March 2024, the six-month period ended on 30 September 2024, and the show-cause notice was issued later. The penalty orders and consequential demand notices were therefore unsustainable, and the appeals were dismissed.

Charitable payment-system infrastructure operated for public benefit remained eligible for exemption under sections 11 and 12 despite transaction-based fees and surplus generation. Fee collection did not by itself establish commercial activity under the proviso to section 2(15), particularly where services were uniformly available at the same fee. No application of income for the benefit of specified persons was established under section 13(3). On identical facts to an earlier coordinate Bench ruling, exemption was sustained for both assessment years and the Revenue's appeals were dismissed.

Valid exercise of the concessional corporate tax option through Form No. 10-IC under section 115BAA continues to apply in subsequent assessment years. Filing the prescribed form, disclosing the option in the relevant return, and prior departmental acceptance support the continuing availability of the concessional rate. Computation at the normal rate during return processing or failure to submit supporting records at the first appellate stage does not negate substantive eligibility where statutory compliance is otherwise established.

Reassessment notices issued to deceased assessees are invalid because the legal-representative provisions permit either continuation of proceedings started during the assessee's lifetime or fresh proceedings directly against the legal representative; they do not permit a notice to be issued in the deceased person's name and later continued against an heir. Consequently, reassessment founded on such a notice is unsustainable and must be quashed. Where jurisdiction fails at the notice stage, challenges to the underlying additions need not be adjudicated and remain open.

Registered societies returning income in the status of an association of persons or body of individuals are considered for normal tax rates where returned total income remains below the taxable limit. Application of the maximum marginal rate under section 167B is not warranted in those circumstances. Tax computation should therefore follow normal rates, and a return showing income below the taxable limit results in no tax liability.

Exclusivity fee received in cash for an aborted joint venture involving transfer of subsidiary shares is a capital receipt where the agreement merely restricts negotiations with other prospective buyers and does not restrict business activities. The monetary receipt falls outside the then-applicable scope of business benefits, and the non-compete provision does not apply because no business activity was restrained. The fee is therefore not taxable under normal provisions or while computing book profit, and its credit to capital reserve stands. Expenditure disallowance relating to exempt income cannot apply where no exempt income was earned; the later explanatory amendment operates prospectively from AY 2022-23.

Gross sale consideration from alleged penny-stock transactions cannot be treated as undisclosed income without examining the underlying transactions and establishing a cogent nexus between the taxpayer and the alleged accommodation-entry arrangement. Recorded books, contract notes, bank statements and broker entries require specific contrary material before being disregarded. General investigation material describing a penny-stock modus operandi may justify further enquiry but does not, by itself, prove that particular transactions are fictitious or represent unaccounted money. A premise that exempt capital gains were claimed must also be supported by the return and computation. Interest on such an addition is consequential and must correspond to finally determined income.

Educational activities comprising banking-industry examinations, training programmes and related instruction qualify as charitable education where they equip banking personnel to perform their functions efficiently. Restricting benefits to a section of the public does not negate charitable character, and refusal of approval under a separate educational-institution regime does not determine exemption under charitable-trust provisions. Tax-free bond interest required no separate relief where exemption governed the institution's income computation. No depreciation disallowance arose because depreciation was not claimed. Accumulation of charitable income was permissible because the prescribed form identified definite purposes, including premises acquisition and renovation and development of educational, testing and data-centre facilities, rather than general objects.

Transfer pricing requires selection of the most appropriate method based on transaction nature and comparable-data reliability, with neither CUP nor TNMM having statutory priority. An external CUP based on an associated enterprise's purchases from independent suppliers may be reliable where geographic, volume or timing differences do not materially affect price or can be reasonably adjusted. TNMM may be unreliable without meaningful adjustment for abnormal fixed costs from low capacity utilisation. Foreign-currency borrowings and receivables require currency-specific benchmarking under comparable uncontrolled conditions. Delayed export receivables constitute separate international transactions, with interest benchmarked at LIBOR plus 200 basis points after a 60-day credit period.

Section 153C jurisdiction was upheld by the majority because both Assessing Officers recorded satisfaction that seized material related to the assessee and affected income determination. No prescribed period governed satisfaction by the Assessing Officer of the other person, and assessment limitation ran from transfer of the seized material. Natural justice did not require supplying statements or permitting cross-examination because the addition rested on seized electronic records rather than witness statements. The seized Excel sheet was treated as corroborated evidence of unexplained investment in a jointly acquired bungalow, as its transaction particulars matched the registered sale deed. The addition remained sustained, subject to verification of the assessee's ownership share and proportionate adjustment.

Recurring trademark fees paid under a non-exclusive, time-bound licence are revenue expenditure where proprietary rights remain with the licensor. The enduring benefit test requires examination of whether the agreement transfers ownership, exclusive rights, or a lasting capital asset. Limited permission to use a trademark, coupled with an obligation to stop using it on termination, does not create such an asset. Annual fees calculated as a percentage of gross profit are recurring operational payments and remain deductible as revenue expenditure. The disallowance of the licensed trademark fee was therefore deleted.

Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed.

Penalty for inaccurate particulars in professional-fee claims requires substantiated expenditure and independent findings supporting concealment or inaccurate particulars. A payment characterised as professional fees but shown to be a loan advanced and repaid, with a corresponding receipt credited to profit and loss, is revenue neutral and does not support disallowance or penalty. Conversely, penalty remains justified where claimed payees deny receipt or payments remain unsubstantiated. Liability to deduct tax on professional fees depends on satisfying the statutory threshold based on gross receipts in the immediately preceding financial year; older receipt data alone is insufficient. Disallowance for non-deduction of tax does not, by itself, justify penalty.

Deemed concealment under Explanation 3 to section 271(1)(c) may apply where a taxpayer files a return only in response to a notice under section 148 and lacks reasonable cause for not filing the original return. However, the tax sought to be evaded must be computed under clause (c) of Explanation 4 after reducing tax deducted at source before the section 148 notice. Where pre-notice tax deducted at source exceeds the final assessed tax liability, no tax is sought to be evaded and penalty under section 271(1)(c) is not leviable. The penalty was deleted.

Rejection of books of account and profit estimation in a redevelopment project is unjustified where the purported comparable operates at a materially different scale and lacks redevelopment-specific costs. Alleged sales below ready-reckoner value require examination against values prevailing on booking dates, not incomplete data. Cash receipts disclosed under the Income Declaration Scheme may be credited where the disclosure relates to parking-slot sales in the sole redevelopment project. Pending approvals and the occupation certificate support revenue recognition under the project-completion method. An addition based solely on a survey statement cannot be sustained without corroborative evidence.

Customs-duty liability for pilfered imported goods arises independently against a customs-area custodian once it has been approved under the Customs Act. A statutory Port Trust may be approved as a custodian because its conditional civil liability as bailee under the Major Port Trusts Act differs from the statutory obligation owed to Revenue for pilferage. The saving clause governing custodian approval does not prevent approval where the other enactment imposes no corresponding customs-duty liability. The overriding provision applies despite other laws, but liability for pilferage cannot arise for periods preceding the custodian's approval.