Unexplained cash-credit addition was sustained because bank credits claimed as rental income were unsupported by a rental agreement, tenant particulars, property details, or other evidence establishing their nature and source. Rental receipts disclosed from a different entity did not substantiate the separate credits under examination. The failure to produce documentary support at the appellate stage left the asserted rental-income explanation unproved, resulting in the credits being treated as unexplained.

Disclosed agricultural income accepted by the Revenue for the relevant and immediately preceding years can explain the source of cash deposited in a bank account. A deposit made during the demonetisation period does not, solely because of its timing, become unexplained money. Where accepted agricultural income supports the availability of cash, the deposit cannot be assessed as unexplained money and is treated as satisfactorily explained.

Reopening based solely on survey material already available to the Assessing Officer cannot be used to reappraise matters for which scrutiny could previously have been initiated. For Assessment Year 2012-13, reassessment initiated after four years without fresh tangible material constituted an impermissible review and was void. For Assessment Year 2013-14, reopening of a completed scrutiny assessment also required proof of income escapement and failure to make a full and true disclosure of material facts. As the reasons merely revisited examined material and showed neither requirement, the reassessment was invalid as a change of opinion.

Material seized during a search of another person triggers the statutory framework for third-party search assessments under Section 153C. An ordinary assessment under Section 143(3), even where the assessee's case was centralised on the basis of such material, does not meet that framework and is invalid. Selling expenditure comprising commission and miscellaneous expenses cannot be wholly disallowed on the stated facts; the claim may be restricted where warranted. The selling-expense disallowance was limited to 10%, with the balance allowed.

Tax deduction at source under section 195 applied to a payment made to a non-resident because the payment, as confirmed in earlier appellate proceedings, was for non-technical value and did not fall within the specified category of payments not chargeable to tax. No contrary material displaced the findings supporting the payer's default. Consequently, tax was required to be deducted on the non-resident payment, and the finding of default against the assessee remained sustained.

Section 68 requires an assessee to establish investors' identity, financial capacity and the genuineness of share capital and share-premium transactions. The shareholders did not independently respond to notices, and the assessee did not provide adequate material on major investors' financial capacity or sources of investment. It also failed to explain the valuation and basis for the substantial share premium. One investor's disclosed income was disproportionate to the investment, while documentation for other investors was inadequate. Consequently, the assessee did not discharge its evidentiary onus, and the addition for unexplained share capital and share premium remained sustained.

Event-management budgets recorded as matching revenue and expenditure entries do not create taxable income or deductible expenditure where the assessee neither received nor paid the budgeted amounts. Where actual income is limited to a management fee and bank records show no movement of the gross budgeted sums, taxation must be based on real income. Disallowing the corresponding notional expenditure while retaining the matching notional revenue would misread the accounting disclosure and tax unreal income. The budgetary entries therefore cannot support a disallowance.

Long-term capital gains exemption on share sales requires reconsideration where the initial deletion rested on an absence of investigation or adverse material, but subsequently produced material may affect that factual premise. Its merits and evidentiary value require examination after hearing both sides. Income arising under a real-estate collaboration agreement also requires fresh review where the treatment of receipts did not assess the transfer of development rights and land held as stock-in-trade as an integrated transaction. Revenue recognition and the relevant factual material must be evaluated before either addition is sustained or deleted.

Payments to a Singapore non-resident for Turnitin and iThenticate software solutions were not royalty under the India-Singapore DTAA where distribution arrangements granted no interest in, or right to use, the software copyright. The payments related to software supplied for resale to Indian distributors or end-users and did not constitute consideration for use of copyright. As no income taxable in India arose, no tax deduction at source obligation applied, and the related disallowance for non-deduction was deleted.

Section 69A permits an addition for unexplained money where the assessee does not satisfactorily explain its source. Cash deposits were explained as arising from earlier withdrawals from salary and Kisan Credit Card accounts. Bank statements and Kisan Credit Card records substantiated those withdrawals, while the salary income and the existence of the credit account were undisputed. The documented withdrawals made the stated source of the deposits plausible, supporting deletion of the addition for unexplained cash deposits.

Reassessment notice under Section 148 for assessment year 2014-15 was required to be issued by 14 June 2022 after applying the surviving limitation period under the transition to the new reassessment regime. The notice issued on 25 July 2022 was therefore time-barred. Consequently, the reassessment proceedings and resulting reassessment order were void from inception and liable to be quashed.

Foreign tax credit is not denied solely because Form 67 was filed after the due date under Section 139(1) of the Income-tax Act, 1961. The time requirement for filing Form 67 is directory rather than mandatory; therefore, delayed compliance does not by itself defeat entitlement to credit for foreign taxes. Credit remains subject to verification of the relevant facts and computation.

Statutory appellate remedy was available for challenges to a show-cause notice and consequential order, including objections concerning jurisdiction, mechanical adjudication and breach of natural justice. Those grounds were capable of examination through the prescribed appeal mechanism, without any opinion on their merits. The writ petition was disposed of with liberty to pursue the statutory appellate remedy.

Schedule III, carrying a 9% rate, inserts woven and non-woven bags and sacks of polyethylene or polypropylene strips or like material, whether laminated or not, when of a kind used for packing goods. It also inserts flexible intermediate bulk containers. Schedule II, carrying a 6% rate, omits serial entries 80AA and 171A and their associated descriptions.

Madhya Pradesh Goods and Services Tax Rules, 2017 are amended with retrospective effect from 27 May 2020 to permit companies to verify specified GST filings through an electronic verification code. Registered persons incorporated under the Companies Act, 2013 may furnish FORM GSTR-3B returns using EVC from 21 April 2020 to 30 September 2020, and may furnish FORM GSTR-1 outward-supply details using EVC from 27 May 2020 to 30 September 2020.

Registration is mandatory before insurance or reinsurance business may commence through an International Financial Services Centre Insurance Office. Eligibility requires appropriate domestic or home-jurisdiction authorisation, regulatory compliance, fit-and-proper governance, FATF-compliant jurisdictional status, and applicable capital, Net Owned Fund and solvency compliance. Registered IIOs may undertake permitted life, general, health or reinsurance business in freely convertible foreign currency, subject to restrictions on Domestic Tariff Area business. They must maintain resident key personnel, records, KYC and AML compliance, prudential standards and regulatory reporting. The Authority may inspect, investigate, suspend or cancel registration after giving an opportunity for submissions.

For the relevant State GST entry, bus body building includes building a body on the chassis of any vehicle falling under Chapter 87 of the First Schedule to the Customs Tariff Act, 1975. The clarification applies solely for the purposes of that entry and covers chassis of any vehicle within the stated tariff chapter. The insertion is deemed effective from 22 November 2019.

Merchandise exports increased sharply in August, led by petroleum product shipments, while imports also rose year-on-year. Reduced gold imports contributed to a narrower merchandise trade deficit. During the first five months of the fiscal year, the cumulative deficit widened as higher imports reflected domestic expansion, energy requirements and manufacturing-input demand. Energy commodities and electronic goods were principal contributors to the deficit, while export growth was supported by engineering goods, petroleum products, chemicals and textiles.

Bribery allegations concerning CGST redevelopment approvals led to registration of a case against a CGST Superintendent and unknown persons. The Superintendent allegedly sought undue advantage for issuing a no-objection certificate and handing over CGST-owned flats. Following verification, a trap was laid after the complainant was allegedly directed to deliver cash to a CGST consultant. Both the Superintendent and consultant were arrested, produced before the competent court, and placed in police custody. Further investigation remains in progress.

Foreign Trade Policy, 2023 introduces a de minimis exemption from the requirement to hold a Registration-cum-Membership Certificate (RCMC) or Certificate of Registration for export consignments whose Free-on-Board (FOB) value does not exceed Rs. 3,00,000. Export consignments exceeding the prescribed FOB-value threshold remain subject to the requirement to possess a valid RCMC or Certificate of Registration wherever that requirement otherwise applies.