Penalty for concealment or furnishing inaccurate particulars cannot be sustained where the statutory notice retains both charges without identifying the precise default, denying the taxpayer a definite charge to answer. A penalty order issued in the name of an entity that ceased to exist on amalgamation is also unsustainable, particularly where that status was disclosed and the underlying assessment in that name was quashed. Further, restriction of licence-fee expenditure does not establish concealment or inaccurate particulars where material facts were disclosed and no incorrect facts were asserted. These defects remove the jurisdictional and factual basis for penalty.

Cancellation of charitable registration under Section 12AB(4) requires a prior inquiry, satisfaction of a specified violation, and a notice identifying the relevant violation with a reasonable opportunity to respond. General notices that combine the inquiry and cancellation stages, or rely on allegations not put to the trust, do not meet that procedure. Cash deposits already accepted as disclosed fee income cannot establish non-genuine charitable activity. Alleged benefits to specified persons through asset-related payments fall for assessment under Section 13(1)(c), unless evidence establishes non-charitable application, diversion, or activities outside charitable objects; they do not alone constitute a specified violation warranting cancellation or refusal of renewal.

Faceless-assessment requirements under sections 144B and 144C do not invalidate an assessment made by the jurisdictional Assessing Officer where the faceless procedure does not apply and statutory assessment notices were issued. Best-judgment assessment and rejection of books under sections 144 and 145(3) require established material irregularities or substantial accounting discrepancies. In share-trading businesses, broker-ledger entries, contract notes and adjustments of sale proceeds against purchases may explain absent bank entries. Gross-profit estimates must address relevant material, identify accounting defects and rest on a rational, methodical basis suited to the business; unsupported profit rates cannot sustain an addition.

Trust registration requires both charitable objects and prima facie evidence that the trust carries on genuine charitable activities. Educational objects in a trust deed do not alone establish genuineness where accounts and responses fail to identify educational institutions operated or managed by the trust, statutory recognition, or verifiable details of students and staff. Leasing premises to another entity that runs an educational institution, and receiving lease rent, does not demonstrate the trust's own educational activity unless the trust establishes its charitable role or application of rental income to charitable purposes. Registration was therefore not grantable.

Tax deduction at source applies to external development charges paid to Haryana Shehri Vikas Pradhikaran. Statutory creation and performance of functions resembling governmental functions do not make the authority "Government" for the relevant statutory exclusion. Applying the jurisdictional High Court's binding determination, failure to deduct tax at source on those payments results in the payer being treated as an assessee in default.

Reassessment notices and consequential orders were invalid where the recorded reasons rested on unverified and factually incorrect information. For one assessment year, reopening proceeded on the false premise that the assessee had not filed a return, and transaction descriptions were ambiguous. For the other, the notice lacked transaction-wise and party-wise particulars, incorrectly characterised bank transactions and amounts advanced as undisclosed income, and relied on an unverified aggregate. A substantial later reduction in the alleged escaped income reinforced the lack of verification. These defects established non-application of mind both in recording reasons and granting statutory approval, requiring the notices and consequential reassessment orders to be quashed.

A BOT road-concessionaire may deduct a scientifically estimated provision for future major repairs when enforceable contractual maintenance obligations have accrued during the accounting year. Periodic repair duties, consequences of breach, and defect-cure obligations on termination establish a present business liability. Where the provision is based on a detailed and reasonably certain estimate, supported by subsequent actual expenditure, deferred quantification or payment does not make it contingent. The provision for major repairs is therefore an allowable deduction despite the expenditure being incurred in a later period.

Retired employees seeking exemption for leave encashment under the enhanced limit effective from 1 April 2023 may pursue statutory remedies under the Income-tax Act, 1961, including filing revised returns where available. The writ petitions were disposed of with liberty to use those remedies, while preserving all rights and contentions. No substantive determination of eligibility for the enhanced exemption or the availability of revised returns was made.

No pending assessment proceedings concerning the respondent left a writ petition challenging an advance ruling without any surviving matter for consideration. The High Court therefore disposed of the petition without adjudicating the challenge on its merits, while preserving liberty to reopen the matter if assessment proceedings concerning the respondent were subsequently found to be pending in fact.

Amounts already assessed or considered in an original assessment cannot support a further addition merely by being recast as bogus construction expenditure or fictitious long-term capital loss. Where reassessment concerns an issue examined under section 143(3), fresh information or material is required to support reopening. Concurrent factual findings that the amounts were already considered, coupled with the absence of new material, do not raise a substantial question of law under section 260A. The appellate deletion of both additions therefore remains undisturbed.

Retention of seized cash under Section 132B cannot continue after completion of the searched person's assessment where no demand relating to the cash was raised and the cash was accepted as belonging to a non-searched assessee. Reassessment proceedings subsequently initiated against that non-searched assessee do not preserve the statutory charge or justify continued withholding. Release of the net seized amount, after adjustment of the stated tax liability, was directed. Whether the cash could initially have been treated as self-assessment tax remains for determination in the admitted appeal.

Land-acquisition compensation payable under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 is treated as not subject to income-tax deduction. TDS deducted from such compensation is refundable to legal heirs. Non-filing of returns for the relevant assessment year and the absence of a condonation application do not by themselves defeat the refund claim, where the heirs can seek condonation and file the prescribed return. On receipt of the required application and return, the delay should be condoned, the return processed, and the TDS refunded.

Classification of a co-operative bank's deposits as unsecured loans was challenged because the assessment entry conflicted with the balance-sheet treatment. The assessment order was quashed to enable the taxpayer to receive an opportunity before the assessing authority. The merits of whether the deposits could properly be treated as unsecured loans were left open, and revenue authorities may issue notice and conduct fresh proceedings in accordance with law.

Section 119(2)(b) permits condonation of delayed compliance where refusal would cause genuine hardship. A two-day delay in filing Form No. 10B for a trust's Section 11 exemption, attributed to portal-related technical difficulty or inadvertent error, warranted a liberal and justice-oriented assessment of reasonable cause and hardship. Denial would have deprived the trust of its claimed exemption and created a substantial tax liability. The delay was condoned, the rejection of the condonation application was set aside, and the return was required to be processed by treating Form No. 10B as timely filed.

Section 270AA penalty immunity is unavailable where Section 270A proceedings concern under-reporting resulting from misreporting, including failure to produce accounting records relating to the relevant income. Identification of proceedings as involving under-reporting due to misreporting may be sufficient even if the notice does not name a specific Section 270A(9) sub-category, where the assessment basis has already informed the taxpayer of the alleged default. In those circumstances, omission of the sub-category does not by itself breach natural justice, and the statutory timeline for disposing of an immunity application does not invalidate rejection outside the misreporting-immunity framework.

Service of a show-cause notice under Section 148A(1) on the correct person is a jurisdictional precondition for an order under Section 148A(3) and a reopening notice under Section 148. Initiating reassessment against a deceased assessee is invalid where the Department had already registered the legal heir. Section 159 permits proceedings against a legal representative but does not permit initiation against a deceased person followed by substitution of the legal representative. The legal heir's participation and jurisdictional objection cannot cure the foundational defect, rendering the consequential reassessment proceedings unsustainable.

Royalty treatment under a DTAA was raised in relation to payments for computer software supplied under a non-exclusive, non-transferable licence. The issue concerned whether such arrangements confer copyright rights, particularly a right to reproduce the software, or merely permit use of off-the-shelf or shrink-wrapped software. The Special Leave Petition was dismissed because similar Special Leave Petitions had been dismissed.

Special Leave Petitions concerning whether advertisement and market promotion expenditure constituted an international transaction, the use of the bright-line test, TNMM-based benchmarking and segmentation, comparability selection, and protective transfer-pricing adjustments were dismissed because Revenue did not satisfactorily explain substantial filing delays. The question of law on these transfer-pricing issues remained open, so the dismissal did not determine the substantive principles.

Penalty under sections 271D and 271E requires the concerned Assessing Officer to record satisfaction during reassessment proceedings before initiating penalty action. The Supreme Court dismissed the special leave petition both for delay and on merits, thereby confirming the High Court's order on this requirement.

Cross-head ITC reporting discrepancies involving allocation of eligible IGST credit under CGST and SGST heads do not, by themselves, establish excess ITC availment under Section 73. Where aggregate ITC entitlement remains unexceeded, the credit's underlying eligibility is undisputed, and no revenue loss is established, the electronic credit ledger must be verified across IGST, CGST and SGST heads. If sufficient eligible IGST credit remained available and unclaimed, the principal ITC demand cannot survive; consequential interest and penalty must also be dropped.