WhatsApp records recovered solely from a third party's mobile phone cannot support an unexplained-investment addition unless their authenticity is established and independent corroborative evidence exists. Electronic records require the prescribed certificate for admissibility, and the material must also comply with the stated requirements for extraction of electronic evidence. A search presumption arising from material found with a third party does not bind the assessee. Because the chats were unauthenticated and unsupported by other evidence, the unexplained-investment addition was deleted and the appeal was allowed.

Live broadcasting rights, characterised as a one-time transmission without an enduring benefit, are neither a scientific work nor rights in which copyright subsists. Licence fees for those rights therefore fall outside royalty treatment under the India-UK DTAA, unlike non-live repeat telecasts and highlights. A mutually agreed allocation of broadcasting fees between live and non-live rights remains valid absent material showing that the allocation is unjustified. Release fees received for permitting athletes to participate in a league, being separate from player remuneration and not arising from athletes' personal activities, fall outside the athlete-income provision of the India-UK DTAA.

Mutual current-account transactions involving repeated advances, repayments and payments made on another concern's behalf are commercial dealings rather than loans or advances for deemed-dividend purposes. Ledger evidence showing that receipts merely repaid earlier advances supports exclusion from the deemed-dividend provision. Likewise, an alleged unsecured loan cannot be treated as unexplained cash credit where records establish interest-bearing commercial entries and no fresh loan arose in the relevant year. On these findings, deletions of both additions were sustained and the Revenue's appeal was dismissed.

Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.

Tax deducted at source that is subsequently deposited into the Government Treasury should not remain recoverable as principal TDS liability once the remittance is verified. Interest for delayed remittance continues to apply, but only up to the actual date of deposit; challans, payment dates and correlation with the demand require verification before recomputation. Renewable Energy Certificate registration charges require examination of the payment's nature, recipient, supporting invoice or demand, and statutory basis. Where the charges qualify as statutory or registration fees not subject to TDS, the related demand and interest should be deleted; otherwise, liability must be determined under the applicable law.

Year-end estimated expenditure provisions, where invoices, precise liabilities and payees remain unascertained, do not amount to credit of an ascertainable sum to an identified payee under the mercantile system. Tax-deduction obligations therefore arise only when liabilities crystallise, with tax deducted where applicable upon receipt of invoices; reversal of the provisions in the succeeding year supports that treatment. A demand for tax-deduction default cannot be sustained merely on creation of such provisions. Further, where the same non-deduction has already led to disallowance of expenditure, it cannot also support a tax-deduction default demand; consequential interest fails with the principal demand.

Companies struck off under the Companies Act continue to exist for purposes of realising dues and discharging outstanding liabilities. Statutory saving provisions preserve the enforceability of liabilities against persons managing the company; therefore, assessment or reassessment is not invalid merely because the company has been struck off. Where the first appellate authority has not examined an unexplained-credit addition on merits because of non-appearance, fresh appellate consideration is required after providing an opportunity of hearing and allowing supporting material to be produced.

Deemed-dividend treatment requires a payment by a closely held company to have the character of a loan or advance to a substantial shareholder. Where a running account shows a continuous credit balance in the shareholder's favour, payment by the company discharges its pre-existing liability rather than creating shareholder indebtedness. Repayment or withdrawal against amounts already due to the shareholder therefore does not constitute deemed dividend. The real nature of the current account and movement of funds must be assessed; a payment's classification cannot rest solely on money moving from company to shareholder. Absence of a loan agreement, interest terms or board approval does not convert repayment into a loan or advance.

Capital-gains computation for an unquoted equity-share transfer uses the consideration actually received or accruing from that transfer; a notional value may replace it only under an express statutory fiction. The prescribed fair-market-value substitution did not apply where the declared consideration exceeded fair market value. Demat records and contemporaneous delivery instructions established completion of the earlier transfer, and later settlement of the purchaser's liability could not alter its transfer date or consideration. A subsequent transfer under a different ownership and contractual structure could not substitute its consideration for the earlier transaction, particularly where conditions had not crystallised the final price. The capital-gains addition was therefore deleted.

Section 54EC exemption for long-term capital gains may apply where specified bonds are purchased within six months of transfer across two financial years. For Assessment Year 2013-14, the investment ceiling operated independently for each financial year when the six-month period overlapped them, rather than as a single transaction-wide cap. The later amendment imposing an aggregate cap for the year of transfer and the succeeding financial year did not apply. Accordingly, restricting the exemption to one financial year's ceiling was set aside and the disallowance was deleted.

Scheduled Tribe income exemption applies only where the taxpayer establishes income from a valid, bona fide source within the statutory conditions. Cash deposits treated as unexplained money do not become exempt solely because the taxpayer is a Scheduled Tribe member residing in a specified State. Bank statements, without books of account or other evidence establishing the source, are insufficient to prove the character of deposits. Consequently, additions for unexplained cash deposits remain taxable and the claimed exemption is unavailable.

Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.

Burden of proof for reclassification rests on Revenue where imported lead-bearing powder is proposed to be classified as lead waste and scrap rather than declared lead concentrate. Conflicting scientific reports that identify principally lead oxide and lead sulphate, with only negligible metallic lead, do not conclusively establish classification under tariff item 78020090. Heading 7802 concerns lead in metallic or primary form, while lead oxide and lead sulphate fall separately within Chapter 28. Technical literature and import-export descriptions cannot displace the declared classification without reliable scientific proof of the goods' identity.

For an RBI-regulated NBFC, breach of binding prudential norms may constitute conduct prejudicial to the company or public interest when assessed cumulatively with related-party dealings, inadequate compliance controls and governance failures. Regulatory penalties do not necessarily preclude oppression and mismanagement jurisdiction, because regulatory supervision and corporate-protection remedies address distinct concerns. Transactions involving related parties require demonstrable approval, documentation, security and recovery arrangements; retrospective omnibus approval may not validate earlier transactions. Resignations of compliance personnel and removal of independent directors may be relevant indicators of weakened governance safeguar.....

Operational debt may arise from an advance paid for goods where a consortium agreement assigns supply obligations to the corporate debtor and other evidence establishes the commercial nexus; an invoice is not indispensable. Receipt of the advance, cheques issued by the corporate debtor, and a later withdrawn invoice supported characterisation as payment for supplies rather than an unsupported security deposit. A pre-existing dispute must exist before the demand notice; post-notice objections and account-reconciliation assertions do not suffice. The insolvency application was revived for admission, subject to a time-bound opportunity for the corporate debtor to prove payment.

Taxable value of commercial training and coaching excludes separately supplied study material, hostel accommodation, mess facilities and ancillary collections lacking a nexus to coaching. Study material, treated as a distinct sale through separate invoicing and accounting, qualified for the pre-negative-regime exemption where no input credit was availed. Other fees require allocation by their actual nature, with non-taxable components excluded and unresolved allocations re-determined. Receivable entries alone did not establish unpaid tax, and the department had to prove that ancillary income arose from taxable service. Rental to a qualifying educational institution was exempt. Extended limitation failed absent suppression, and reasonable cause supported penalty relief. Service tax remained applicable only to tuition charges where applicable.

Revenue cannot treat Business Auxiliary Services supplied to a foreign recipient as non-exported for Rule 5 CENVAT-credit refund purposes while not seeking recovery of service tax on the inconsistent premise that those same services were taxable in India. Category III services supplied in relation to business or commerce qualify as exports where the recipient is outside India and the benefit accrues outside India, even if activities are performed in India. Accumulated CENVAT-credit refund claims are therefore admissible for qualifying services.

Comparable-service valuation under service-tax rules requires comparison between service recipients who stand on the same footing. Flats and a commercial unit allotted without monetary consideration to existing occupants under a redevelopment arrangement could not be valued by reference to sale prices of flats sold to new buyers, because the two recipient groups were not comparable. Since service tax had already been discharged on flats sold to new buyers, the demand based on an assumed value for allotments to existing occupants was unsustainable. The service-tax demand, consequential interest and penalty were set aside.

Tax audit under section 44AB applies independently of a presumptive-income declaration under section 44AD. Where cash receipts and cash payments exceed 5%, the enhanced audit threshold is unavailable and the normal Rs. 1 crore business-turnover threshold applies. Turnover of approximately Rs. 1.37 crore therefore requires tax audit under section 44AB(a), even where profit is declared above the section 44AD presumptive rate. Separate commission income does not alter the audit consequence arising from business turnover.

Sugar retail and wholesale prices remained elevated despite measures intended to curb price increases, including duty-free imports of raw sugar, tighter stockholding norms for bulk users and dealers, and a prohibition on sugar exports. Ex-mill rates declined following the permitted duty-free imports, although customary margins continued between ex-mill, wholesale, and retail prices. Projected sugar production is lower than earlier estimates, while annual domestic demand remains substantial.