Natural justice does not invariably require oral hearing where written submissions provide an effective opportunity of representation and are considered in adjudication. Refusal of an adjournment for oral arguments, despite consideration of the Revenue's detailed written submissions and material contentions, does not by itself establish prejudice or denial of natural justice. Rectification under Section 254(2) is confined to a material contention apparent from the record having been overlooked and causing prejudice; it cannot be invoked to seek a merits review because additional oral submissions were not permitted. Recall or rectification was therefore not warranted.

Section 69A does not apply to cash deposits recorded in books and traceable to disclosed cash sales or debtor realisations merely because the explanation is doubted. Where turnover and business profits remain accepted, and no evidence establishes fictitious sales, an unrecorded source, or material outside the books, a separate addition for unexplained money would duplicate taxation of disclosed business receipts. Rejection of books under Section 145(3) requires specific defects preventing correct income determination; suspicion based on cash-receipt patterns or cash retention, without inquiry or evidence of falsity, is insufficient. Recorded cash from accepted business turnover therefore cannot be separately assessed as unexplained money.

For Assessment Year 2025-26, Section 87A grants a full rebate to a resident individual governed by Section 115BAC(1A) whose total income is within the prescribed limit, including against tax attributable to short-term capital gains taxable under Section 111A. The first proviso to Section 87A, applicable from Assessment Year 2024-25, contained no exclusion for special-rate income. The Finance Act 2025 exclusion of such income applies only from Assessment Year 2026-27 and does not affect Assessment Year 2025-26. Consequently, eligible taxpayers may claim the rebate against tax on qualifying short-term capital gains for that year.

Section 54F deduction for construction of a residential house requires construction within three years of transfer and evidence supporting the eligible investment. A local-authority certificate and registered valuer's report supported timely construction of the residential house and the related construction expenditure. Expenditure claimed for furniture and fixtures lacked sufficient supporting evidence and was excluded from the eligible investment. The resulting computation allowed deduction for the supported residential-house construction and determined the remaining long-term capital gain after excluding unsupported furniture and fixture costs.

Reassessment cannot sustain a disallowance of deduction under Section 80P where no addition is made on the cash deposits and time deposits that formed the recorded reasons for reopening. Under the applicable jurisdictional principle, failure to make an addition on the reopening issue prevents assessment of another issue in that reassessment. The Section 80P deduction disallowance was therefore beyond the permissible scope of reassessment and was deleted.

Survey surrender income credited to the profit and loss account and offered as business income was subject to the normal tax rate for Assessment Year 2017-18. Section 115BBE's enhanced rate took effect from 1 April 2017 and, without express retrospective operation, applied from Financial Year 2017-18, corresponding to Assessment Year 2018-19. Where two reasonable interpretations of a taxing provision were available and no jurisdictional High Court ruling governed the issue, the interpretation favourable to the taxpayer applied. The enhanced rate therefore did not govern the surrendered income for the relevant assessment year.

Obsolete inventory may be written down to net realisable value under Accounting Standard-2's lower-of-cost-or-net-realisable-value principle where the valuation is consistently applied and supported by audited accounts, physical verification, item-wise stock records, business discontinuance and auditor certification. A higher value cannot be substituted merely on presumed scrap value, lack of technical certification, non-disclosure to a banker or later stock-summary omissions. Independent valuation evidence, comparable sales, market quotations, scrap valuations or other positive material is required to establish a higher realisable value. Acceptance of the closing stock as succeeding-year opening stock further supports the commercial basis of the write-down.

Summary processing under Section 143(1) may occur before regular scrutiny assessment begins. Once notice under Section 143(2) initiates scrutiny proceedings, a later intimation under Section 143(1) is unnecessary and impermissible. Where the scrutiny notice predates the summary intimation, the intimation is void from inception; adjustments made through it cannot stand, and the returned income must be accepted.

Section 69A applies only where money is unrecorded in the books and its nature and source lack a satisfactory explanation. Cash deposits linked to cash-book entries, documented paddy sales, financial statements and business financing require evidence that the recorded transactions are fictitious before they can be treated as unexplained money. Unrejected books and an undisproved stock, purchase and sales trail prevent recharacterisation of recorded business receipts, avoiding taxation of the same receipt under two characterisations.

Reassessment cannot sustain an addition on an issue outside the recorded reasons when the addition on the reopening issue does not survive. The land-transaction addition that prompted reassessment was deleted without challenge by the Revenue. Consequently, the separate addition under Section 50C for short-term capital gains from sale of shops, being unrelated to the recorded reasons, was deleted in favour of the assessee.

Before 1 April 2025, the Joint Commissioner held authority to impose penalties for contravention of Section 269SS, while the Assessing Officer lacked jurisdiction to initiate or impose penalty under Section 271D. Accordingly, an Assessing Officer's failure to initiate such penalty proceedings could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision purposes under Section 263. Revision on that ground was therefore invalid, and the revision order was set aside in favour of the assessee.

Sanction under Section 151 of the Income-tax Act is a jurisdictional condition for reassessment notices issued after the applicable three-year period. For assessment year 2017-18, a notice issued after 31 March 2021 required prior approval from the prescribed Principal Chief Commissioner-level authority. Approval by a Principal Commissioner did not satisfy that statutory requirement. Consequently, the reassessment notice was invalid because it lacked sanction from the specified authority.

Clause 2(c) of the 2006 waiver/reduction order permits interest relief only where non-payment resulted from a jurisdictional High Court order governing the assessee when advance tax was payable or the return was filed, and where the full principal tax demand has been paid. Returns filed before the relevant judicial ruling cannot satisfy the reliance requirement; failure to pay the principal demand also defeats relief. Provisions on interest following reassessment or recomputation do not invalidate a refusal of waiver. Interest under Section 220(2) arises on default after a demand notice, and any excess levy claim requires consideration by the competent authority, including a possible refund.

Approved resolution plans bind all stakeholders and enable a corporate debtor to resume operations on a fresh slate. Income-tax arrears not submitted before the committee of creditors and not included in the resolution plan are frozen upon the adjudicating authority's approval. Such unclaimed tax demands do not survive against the corporate debtor after approval, preventing recovery of liabilities excluded from the plan.

Reassessment notices must be issued to a legally existing entity. Where a merger takes effect and the erstwhile entity ceases to exist, a notice issued in that entity's name is legally unsustainable, particularly where revenue authorities were informed of the merger and the successor continued the business. The reassessment notice for the relevant assessment year was quashed because it was addressed to the dissolved merged entity.

Technical impediments to online filing of a GST appeal, despite an alleged pre-deposit of disputed tax, raise a prima facie access-to-justice concern affecting the statutory right of appeal. Instructions were sought on establishing permanent online filing measures and, if unavailable, permitting offline filing. The appeal's maintainability remains open for independent consideration after filing, while the matter awaits further hearing following time granted for instructions.

Input tax credit under Section 16 is a conditional statutory entitlement: the recipient must establish eligibility, including that the supplier has paid the tax. Section 16(2)(c), read with Section 41, permits reversal of credit for supplier default and re-availment after payment, and is not subject to a bona fide-purchaser exception. Allegations of fake invoices, bogus supplies and absence of goods movement may provide the prima facie foundation for proceedings under Section 74, while their evidentiary correctness requires merits review. Form GST DRC-01A is not a mandatory precondition under Rule 142(1A), and investigation and determination by the proper officer do not alone establish bias. Transactional disputes are to be pursued through the statutory appellate framework.

GST assessment proceedings may be restored for fresh merits adjudication despite expiry of the appellate limitation where the taxpayer substantiates medical incapacity during the relevant period, had promptly pursued rectification, and undertakes to comply with specified conditions. The assessment was quashed subject to deposit of 10% of the disputed tax and submission of a reply with supporting documents, enabling fresh consideration of the taxpayer's position.

The ten-percent penalty pre-deposit proviso under Section 107(6) applies only where the adjudication order demands penalty without any demand of tax. Where an adjudication order confirms tax, interest and penalty but appropriates tax and interest already paid, it remains an order involving a tax demand. A later recovery order limited to penalty does not change that character. Consequently, the penalty-only pre-deposit requirement does not apply, and rejection of the statutory appeal for non-compliance is invalid; the appeal requires adjudication on merits.

Supplier certificates supporting receipt of supplies and GST payment provide prima facie support against a disputed GST demand, but must accurately identify the recipient's GSTIN where the supplier's GSTR-1 contains an erroneous recipient entry. A corrected certificate including the omitted GSTIN particulars was required for fresh adjudication. The disputed tax order was set aside and remanded for reconsideration, subject to the stipulated deposit.