Assignable contractual rights, including rights reinforced by a specific-performance decree to obtain conveyance of immovable property, are property and capital assets. Their assignment for consideration is a transfer taxable as capital gains rather than income from other sources, even where title or possession has not passed. Claims for indexed cost of improvement and residential-investment exemption require verification of supporting records and fresh adjudication. In alleged penny-stock share sales, surrounding circumstances may, on a preponderance-of-probabilities assessment, displace banking and demat documentation and require the taxpayer to establish genuineness. Unusual off-market acquisition, abnormal market movement and lack of credible investment rationale supported treatment of proceeds as unexplained cash credit.

Domestic enforcement of the MFN clause requires a notification under section 90(1). The notification modifying Article 11(2) of the India-Netherlands DTAA reduced source taxation of interest for beneficial owners but did not incorporate the exemption for government-approved debt claims in the India-USA DTAA or a comparable India-Italy DTAA exemption. In the absence of a specific notification extending a nil rate, interest on income-tax refunds under section 244A remains taxable at 10% under Article 11(2) of the India-Netherlands DTAA.

Interest earned by a co-operative credit society on temporary deposits of funds not immediately required for lending to members is attributable to its business of providing credit facilities. Such interest qualifies for deduction under Section 80P(2)(a)(i) where the deposits represent the society's own deployable funds rather than amounts retained for, or payable to, members. The separate deduction applicable to investments with another co-operative society does not govern this position. Interest on bank deposits was therefore treated as qualifying business income, requiring deletion of the addition made for non-qualifying income.

Section 54B exemption for reinvestment in agricultural land was allowable where a co-owner's identical claim, based on the same sale and reinvestment, had been accepted in reassessment; the corresponding claim could not be denied for either assessment year. Agricultural income could not be newly assessed as income from other sources at appellate stage where the original assessment had not addressed that taxability and no notice of enhancement under section 251(2) was issued. The additions were unsustainable and excluded from taxable income.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the Revenue. Enquiries into trademark acquisition, capitalisation and depreciation, including supporting bills, financial statements and explanations, may support a plausible assessment view without a mandatory valuation report. The distinction between absence of enquiry and inadequate enquiry remains material despite Explanation 2(a); a revisionary authority cannot replace the Assessing Officer's plausible view or order fishing and roving verification merely because further enquiry appears desirable. As these conditions were not established, the revisionary order was quashed and the original assessment restored.

Bank-account attachment pending a restored statutory appeal should be replaced by proportionate security where the appeal has been remitted for fresh decision and remains undecided. Revenue protection is achieved by requiring deposit of 20% of the assessed tax liability within three weeks, after which the accounts must be released. The restored appeal is to receive priority disposal within six months.

Section 69A applies only where the taxpayer does not satisfactorily explain the nature and source of money. Cash deposited during demonetisation was explained as business cash, including advances returned by paddy-procurement agents, supported by cash books, financial statements, agent details and comparative deposit data. As the books were not rejected and available evidence supported the business practice, the source was treated as satisfactorily explained. No addition for unexplained cash deposits was warranted, and the factual finding raised no substantial question of law under Section 260A.

Agricultural treatment of social forestry losses depends on basic agricultural operations on land and operations integrally connected with them. Seed-route cultivation of saplings on land, including consequential pot or polybag operations, is agricultural; landless clonal propagation and post-sale supervision of farmers' trees are business activities for raw-material procurement. The agricultural-loss disallowance, including depreciation, and the corresponding Section 115JB book-profit adjustment were confined to the land-based component. Concealment penalty does not arise where the impugned addition leaves tax liability unchanged under the book-profit regime, because no tax has been sought to be avoided.

Non-resident income is chargeable in India only when received, accrued, arisen, or deemed to accrue or arise there; payer residence or deduction claims alone do not establish situs without a real nexus to the income-producing right or activity. Advance-ruling jurisdiction is confined to the applicant, the stated transaction and incidental questions, and tax-avoidance findings require an identifiable Indian tax incidence. Extended reassessment limitation requires a qualifying asset, transaction or entry belonging to the assessee and disclosure enabling a response. Protective assessment may resolve uncertainty over the correct assessee, but does not authorise protective recovery or indefinite withholding of TDS refunds.

Section 147's Explanation permits a pending reassessment to cover any further escaped-income issue noticed during those proceedings without initiating a fresh Section 148A process. Its scope is not confined to information available at commencement or derived from the original reassessment material, and it applies even if the original issue produces no addition. The omission of "and also" from the amended provision distinguishes precedent based on the earlier wording. Search-derived and other external material may therefore enlarge the pending reassessment, while the search-assessment mechanism remains an alternative route. Plain statutory language in an Explanation can expand the main provision where it clearly conveys that legislative intent.

Refunds arising from TDS assessments and appellate give-effect orders constitute crystallised rights and are not contingent on the pre-assessment processing mechanism for TDS statements or furnishing Form 26B. Section 201 governs TDS assessment, while Section 200A and Rule 31A regulate statement processing and adjustments before assessment. Where give-effect orders are already on departmental record and no refund adjustment order exists under Section 245, refunds cannot be withheld on procedural grounds. Applicable interest remains payable under Section 244A until payment.

Production of income-tax search records under Section 91 CrPC requires a continuing showing that the documents are necessary or desirable at the relevant stage; prior judicial scrutiny of the authorisation and search does not create a general right to repeated disclosure of confidential foundational material. Further production was therefore declined. Recall of a witness under Section 311 CrPC likewise requires that additional examination be essential to a just decision. Where the proposed confrontation depended solely on an unavailable document and the witness had already been substantially cross-examined on the search and recovery, recall was not essential. The procedural orders remained undisturbed, without determining the criminal charges.

Final settlement orders under the income-tax settlement scheme attain statutory finality for matters they cover, including deductions reflected in total income. Once a settlement application proceeds, exclusive jurisdiction over the relevant return and assessment year lies with the Settlement Commission. The Assessing Officer cannot reopen such settled matters through reassessment provisions. Allegations of fraud or misrepresentation must be pursued through the settlement scheme's prescribed mechanism rather than reassessment; rejection of that remedy leaves the final settlement order effective. Revenue authorities may participate in settlement proceedings and place relevant material before the Settlement Commission.

Works-contract services for installing a new main water pipeline and revamping a distribution network involve goods incorporated into immovable property and are treated as supplies of services. New pipeline installation falls under SAC 995422 as civil engineering waterworks, while network revamping falls under SAC 995429 as repair and maintenance, rather than SAC 995479. Exemption for pure or composite supplies is unavailable where the goods component exceeds the permitted limit. Although the recipient is a Governmental Authority, civil engineering and repair work merely connected with water infrastructure is not supplied "by way of" water supply. The services are taxable under the applicable works-contract entry at 9 per cent CGST and 9 per cent SGST.

Imported IT support services received by an Indian recipient from a related foreign entity constitute an import of services where the supplier is outside India, the recipient is in India, and the place of supply is India. IGST is payable by the recipient under reverse charge. For related-party imported services, the invoice-value deeming principle treats the value declared in the recipient's self-invoice as open market value where the recipient is eligible for full input tax credit. This valuation mechanism applies to reverse-charge imports of services.

Electrically operated three-wheeled e-rickshaws, e-carts and hydraulic e-carts are classifiable under tariff heading 8703, while e-scooters fall under heading 8711. Where the vehicle's motor, inverter, control module, drivetrain and body are fitted, supplying it without a battery does not change its essential character as a vehicle propelled solely by electrical energy. The specified two- and three-wheeled vehicles therefore qualify for 5% GST. Refund entitlement for accumulated input tax credit arising from an inverted duty structure falls outside the categories permitted for advance rulings and is not admitted.

Transfer of an entire proprietorship business to an LLP without consideration constitutes a supply under GST where the arrangement transfers assets, liabilities, employees, rights and customer relationships for uninterrupted continuation of the business. A transfer of the business as a whole, when made as a going concern, is classified as a supply of services rather than goods. Nil-rate exemption for transfer of a going concern depends on establishing that the business satisfies applicable going-concern standards. If that status is not established, stock and business assets transferred on cessation are deemed supplies of goods and attract GST at the rates applicable to those goods.

Advance-ruling questions must relate to a supply of goods or services undertaken or proposed to be undertaken by the applicant under the CGST Act. Questions concerning an alleged supply by a faculty member to an institute, including the individual's GST registration and invoicing obligations, do not concern a supply made or proposed by the applicant. Such questions therefore fall outside the statutory scope of an advance-ruling application by the institute and are not maintainable.

GST paid on balance works is separately reimbursable where the accepted Bill of Quantities expressly requires rates "without taxes," notwithstanding a PWD Manual clause contemplating tax-inclusive quoted rates. The tender terms governing the accepted bid prevent the quoted amount from being treated as inclusive of GST. As the Bill of Quantities referred to the sales-tax regime, while the liability arose under GST, and the original tender pre-dated GST for continuation of abandoned works, GST inclusion was not within the parties' contemplation. Reimbursement requires proof of GST payment through relevant GST returns.

Cancelled GST registration may be restored under the applicable revival framework only upon filing all pending pre- and post-cancellation returns and paying tax, interest, penalty, fine and fees in cash. Input tax credit cannot be used for these payments and may be utilised only after departmental scrutiny and approval. Restoration remains subject to compliance with these conditions and consideration of the taxpayer's representation.