Validity of prosecution sanction under the Prevention of Corruption Act cannot be examined at the discharge stage because the statutory bar restricts such challenge at that point. Discharge of the accused in the predicate corruption prosecution on that basis is therefore unsustainable. Quashing of connected money-laundering proceedings, being consequential to the predicate-case discharge, is likewise unsustainable. The validity of sanction and all other issues remain open for determination during trial.

Bail orders may be annulled without supervening circumstances where they are perverse, legally untenable, rely on suspect or irrelevant material, or overlook the seriousness of accusations and criminal antecedents. Suppression of antecedents and other material particulars undermines informed bail discretion and constitutes abuse of process. Applicants should disclose antecedents, prior and pending bail applications, coercive processes, custody details and procedural status by affidavit; an illustrative recommendatory framework promotes transparency. Transfer of a completed investigation after filing of a chargesheet requires cogent evidence of bias, mala fides, improper investigation, extraneous influence, or a need to restore public confidence; absent such material, transfer should be declined.

Settlement of disputed tax liability under Section 24-B of the M.P. VAT Act - Maintainability of settlement application for entry-tax liability - Hardship as a condition for tax settlement Entitlement to seek settlement of entry-tax liability under Section 24-B of the M.P. VAT Act after the reassessment order had attained finality - HELD THAT: - A settlement application under Section 24-B is maintainable where the tax dispute is pending before the High Court and hardship is caused by an order... ... ...

Classification of 10G/100G Small Form Factor Pluggable modules used in routers - Customs Tariff Item 8517 7090 or Customs Tariff Item 8517 6290 - HELD THAT: - Following the earlier Tribunal decisions in the matter of M/s. Vodafone India Pvt Ltd [2025 (1) TMI 556 - CESTAT NEW DELHI] and Reliance Jio Infocomm Ltd [2022 (8) TMI 76 - CESTAT MUMBAI] the impugned goods '10G/100G 'Small Form factor Pluggable (SFP)' are classifiable under Customs Tariff Item (CTI) 8517 7090 and not under Cus... ... ...

Allowability of brokerage expenditure on sale of immovable properties - Annual letting value of unsold flats held as stock-in-trade Brokerage expenditure on sale of immovable properties - Disallowance of brokerage paid for facilitating sales of flats and other immovable properties by restricting the allowable rate - HELD THAT: - The recipient was not a related party, the brokerage had been paid over several years in the ordinary course of business, and the assessee had furnished the requisite... ... ...

TP Adjustment - Arm's length price of corporate guarantees to associated enterprises - Disallowance of expenditure in relation to exempt dividend income Arm's length price of corporate guarantees to associated enterprises - Transfer-pricing adjustment on the corporate guarantee extended to associated enterprises - HELD THAT: - Following the consistent view taken in the assessee's earlier cases AYs 2017-18 [2024 (1) TMI 106 - ITAT CHENNAI], the Tribunal held that the arm's leng... ... ...

Interest disallowance where own funds exceed investments - Disallowance of indirect expenditure relating to exempt income - Prospective operation of amendment to section 14A - Book-profit computation and section 14A disallowance Interest disallowance where own funds exceed investments - HELD THAT: - Following the co-ordinate Bench decision on the same controversy involving the assessee's sister concern [2024 (7) TMI 1682 - ITAT CHENNAI], the Tribunal accepted that, where own funds substan... ... ...

Limitation for reassessment notice - Invalid reassessment proceedings Validity of the reassessment notice issued for assessment year 2015-2016 beyond the prescribed period - HELD THAT: - A reassessment notice cannot be issued after expiry of three years from the end of the relevant financial year. The recorded reasons contained no allegation that the assessee had failed to disclose material facts necessary for assessment; consequently, the notice was invalid in law. [Paras 4] The assessmen... ... ...

Exemption u/s 11 - belated audit report - Section 143(1) adjustment - incorrect exemption claim Eligibility of a registered society to exemption under section 11 where the prescribed audit report in Form 10BB was filed after the specified date - HELD THAT: - Filing the prescribed audit report in Form 10BB within the stipulated time was held to be a condition precedent for claiming exemption under section 11. In the absence of such timely report, the exemption claim constituted an incorrect cl... ... ...

Unexplained cash credit - Cash deposits from cash sales during demonetisation HELD THAT: - The assessee demonstrated a regular pattern of cash sales and corresponding bank deposits, with reconciliation of stock, cash sales and deposits. The deposits during the demonetisation period disclosed no unusual or abnormal feature when compared with the past business pattern. Having accepted the cash sales, the Assessing Officer could not reject the explained source of the corresponding cash deposits.... ... ...

Unexplained investment - burden of proof - Fixed deposit renewals - source of investment Sustainability of addition for unexplained investment in fixed deposits after the source of the deposits was accepted as renewals of existing NRE fixed deposits - HELD THAT: - The certificates issued by the bank branches and the assessee's affidavit satisfied the appellate authority that the fixed deposits represented renewals of earlier deposits and were NRE fixed deposits. Once that source stood acc... ... ...

Unexplained money u/s 69A - bogus unsecured loans - Burden to disprove evidence of loan repayment and interest payment Addition as unexplained money in respect of alleged bogus unsecured loans where evidence of repayments and interest payments was not disproved - HELD THAT: - Though furnishing documents alone did not establish the genuineness of the loan transactions, the Assessing Officer had not verified the evidence furnished regarding the source in the hands of the lenders. The evidence o... ... ...

Order passed on a non-existing entity - Fresh assessment for verification of unexplained cash deposits - Assessment proceedings against entity linked to bank PAN Restoration of the assessment for verification of cash deposits credited in a bank account continuing in the PAN of the dissolved firm, where the assessee claimed that the deposits belonged to a newly constituted firm - HELD THAT: - The initiation of proceedings against the entity whose PAN remained linked to the bank account could n... ... ...

Year of taxability of unexplained investment in property - Addition as unexplained investment for alleged on-money payment towards purchase of a flat for A.Y. 2012-13 HELD THAT: - The Commissioner (Appeals) had recorded that the bearer cheques relied upon for the impugned payment were issued after September 2012. Having accepted that the transaction did not relate to A.Y. 2012-13, the addition could not be sustained in that assessment year. [Paras 6] The addition under section 69 was direc... ... ...

Royalty-management support services - Transfer of know-how - Cost reimbursement Taxability of management and business support service fees received from the Indian subsidiary as royalty under Article 12(4) of the India-Netherlands DTAA - HELD THAT: - Payments for services can be characterised as royalty for information concerning industrial, commercial or scientific experience only where there is an imparting or transfer of know-how enabling its independent use by the recipient. The services ... ... ...

Double taxation of disclosed receipts - Unexplained expenditure - credit card payments through regular bank account Double taxation of disclosed receipts - Estimated profit on contract receipts and service charges - Separate estimation of profit on contract receipts and service charges reflected against the incorrect PAN despite their inclusion in the books and return under the correct PAN - HELD THAT: - Form 26AS showed that the contract receipts standing against the incorrect PAN had been n... ... ...

Jurisdiction under section 153C - date of initiation of search for other person Validity of assessment under section 153C where the relevant date of initiation of search for the other person fell after 1 April 2021 - HELD THAT: - For an other person, the date of initiation of search is to be construed as the date on which the seized material is received by that person's Assessing Officer. Since the satisfaction was recorded after 1 April 2021, section 153C was rendered inapplicable by sub... ... ...

Notional annual letting value of unsold flats held as stock-in-trade - Prospective operation of the statutory framework for stock-in-trade - Strict interpretation of charging provisions - Taxability of notional annual letting value of completed unsold flats held by a builder and developer as stock-in-trade for Assessment Year 2017-18 HELD THAT: - Section 23(5) introduced a specific statutory framework for completed properties held as stock-in-trade, including the prescribed nil annual-value p... ... ...

Penalty u/s 270A for misreporting arising from disallowed political donation deduction - Non Specification of misreporting limb in penalty proceedings Penalty u/s 270A on disallowance of deduction claimed u/s 80GGC - HELD THAT: - Following the co-ordinate Bench decision HIRO MULCHAND TANWANI, AHMEDABAD [2026 (6) TMI 214 - ITAT AHMEDABAD] on an unchanged factual matrix and legal proposition, the Tribunal held that disallowance of a transparently claimed deduction, without material establishing... ... ...

Limitation for reassessment notice issued after midnight - Validity of a reassessment notice signed before the limitation deadline but issued and dispatched after midnight HELD THAT: - The Court followed its earlier determination [2024 (7) TMI 1186 - TELANGANA HIGH COURT], stated to have been confirmed by dismissal of the challenges before the Supreme Court [2025 (6) TMI 1648 - SC ORDER], [2025 (8) TMI 391 - SC ORDER] and [2025 (9) TMI 45 - SC ORDER], on the question whether a notice issued a... ... ...