Professional coaching supplied by an entity that does not itself deliver a recognised qualifying curriculum, conduct examinations or award qualifications is not exempt as education by an educational institution and is taxable. Examination, registration and related student fees remain within taxable value unless all pure-agent conditions, including student authorisation and separate invoice disclosure, are met. Coaching bundled for a single fee with study materials and digital resources is a composite supply whose principal supply is commercial training. Retained foreign-exchange differences unconnected with separate consideration are outside GST. Training-partner services to universities are taxable where no exempt service or educational-institution status is established; insufficient contractual material prevents precise six-digit classification.

Advance-ruling jurisdiction under section 97(2) does not extend to eligibility for refund of unutilised input tax credit arising from an inverted duty structure; that question is therefore not admissible. Heading 4504 covers agglomerated cork with or without a binding substance, without limits on the binder's quantity or nature. Cork sheets formed from agglomerated cork granules held together by a polymer system, rather than cork used merely as a rubber filler, fall under tariff item 4504 10 10 and qualify for the concessional GST entry. The bar applies only where the same question is pending or decided in proceedings concerning the applicant; absent such proceedings, classification and rate questions remain admissible.

Reassessment under Section 147 cannot be used to review conclusions reached in an original scrutiny assessment. Where the Assessing Officer had specifically examined depreciation claims, deductions, exempt-income expenditure and pre-production income, reopening based only on the same assessment record and a successor officer's different inference constitutes a change of opinion. In the absence of fresh tangible material, a false statement, or failure to make full and true disclosure of material facts, no jurisdictional reason to believe that income escaped assessment arises. The reassessment was therefore quashed and the revenue's appeal dismissed.

Search-assessment limitation requires court-ordered stay periods to be excluded within the single composite limitation period before testing whether TOLA extends that date. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge the period available for completing assessments. For years affected by the stay, the composite limitation date fell outside the TOLA window; for the remaining years, the extension operated only until 30 September 2021. The assessments, related notices and consequential penalty proceedings for all nine assessment years were time-barred and quashed, while the merits of the additions remained open.

Reopening of a completed scrutiny assessment is invalid where tax deducted at source on salary payments was not claimed as expenditure or as a statutory deduction, but was mistakenly treated as claimed through a misreading of the tax audit report. Where the deduction position and tax withholding had already been examined and accepted during original scrutiny, reopening on the same material without fresh tangible material constitutes an impermissible change of opinion and demonstrates non-application of mind. The reassessment notice and consequential order were quashed.

Fixed "refurbish and rebate" credit notes issued to distributors for defective products did not constitute consideration for contract work where the credit was uniformly calculated at 30% of the original price, regardless of repair cost or whether repairs occurred, and distributors were not obliged to repair. Consequently, tax was not required to be deducted at source and the related disallowance was deleted. Employees' welfare contributions require verification against statutory due dates using challans and supporting material where the tax audit report's payment dates are disputed. Contributions paid within the prescribed due dates must be allowed; the issue was remanded for limited verification.

For charitable trusts, bank fixed deposits made for six months or more from the net consideration received on transfer of trust property qualify as another capital asset for capital-gains exemption under section 11(1A). CBDT Instruction No. 883 extends the expression to such deposits. Form No. 10 is unnecessary where the consideration has already been invested rather than accumulated for later application. Unrecoverable tax deducted at source may be treated as application of income where no refund has been claimed and the amount has a direct nexus with the trust's income receipts.

Under the India-UK DTAA, telecommunication-service receipts are treated as business profits rather than royalty or fees for technical services where treaty characterisation remains unchanged by unilateral domestic-law amendments absent bilateral renegotiation. On that basis, the taxability challenge concerning those receipts succeeded on merits. Reopening and limitation issues remained open, while a remaining ground was not pressed.

Enhanced penalty for misreporting under section 270A requires identification of a specific statutory category of misreporting and factual findings establishing its ingredients. Mere omission of salary, interest or rental income from a return, followed by detection during reassessment, does not by itself establish misrepresentation, suppression, failure to record receipts, or another prescribed form of misreporting. Under-reporting and under-reporting resulting from misreporting are distinct defaults with different penalty consequences. Where proceedings were initiated solely on the aggravated misreporting charge, an appellate authority cannot recast the levy as a penalty for ordinary under-reporting after the misreporting charge fails.

Ad hoc disallowance of employee-benefit and business expenditure lacks basis where no expenditure is identified as non-genuine, excessive or non-business, and the books are not rejected; missing vouchers justify item-specific verification, not a blanket estimate. Cash deposits attributed to recorded multi-outlet sales cannot be reclassified as unexplained cash credits without evidence that they comprised Specified Bank Notes or that the underlying books, sales or stock records were defective; taxing recorded receipts again produces double taxation. Loan credits require verification of lender records, immediate source, and repayment or adjustment entries; confirmations, PAN details and banking entries require assessment alongside those records, while unsecured or interest-free terms alone do not justify an addition.

Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted.

Employee long-term reward insurance premiums do not qualify as wholly and exclusively incurred for business where policies on directors' lives are not Keyman Insurance Policies, policy proceeds vest in the directors or their nominees, and the company receives no ultimate benefit. Premium deductions were therefore denied for the relevant assessment years. Reassessment may rest on later scrutiny findings where earlier acceptance did not involve examination of policy terms; each assessment year is separate and res judicata does not strictly govern income-tax proceedings. A change-of-opinion objection fails absent prior scrutiny of the claim. A challenge alleging no statutory approval for a reassessment notice requires supporting material or evidence that approval was sought.

Transfer-pricing adjustment for operational-expense reimbursements to foreign associated enterprises was deleted because the Other Method was applied without identifying an uncontrolled price or comparable transaction, and transfer pricing cannot test expenditure allowability or genuineness where no mark-up, inflated pricing, or non-business spending is established. Unutilised foreign tax credit relating to income taxed in earlier years cannot be claimed later as a business deduction: Rule 128 confines credit to the year corresponding income is offered or assessed in India. Payments to non-resident recruitment, legal and tariff-publication providers did not attract withholding absent proof of Indian taxability; tariff publication did not make available technical knowledge. The related disallowance was deleted.

Rural agricultural land does not constitute a capital asset for income-tax purposes. Compensation received on its compulsory acquisition under the RFCTLARR Act is exempt from income tax, applying Circular No. 36/2016. Accordingly, such compensation cannot be assessed as short-term capital gain, and the addition made on that basis was deleted.

Recorded cash sales deposited during demonetisation cannot be treated as unexplained where books, sale bills, stock records and cash balances are accepted, since this would tax the same receipts twice. Rental income reflected in Form 26AS requires reconciliation and verification, with corresponding relief or tax credit where warranted. Business expenditure remains disallowable where the claim that tax withholding was unnecessary is unsupported. A challenge to penalty initiation before a penalty order is premature. Alleged unexplained receipts in a running account must account for debit entries and repayments rather than aggregate gross receipts. Reversal of overdraft interest is not taxable as cessation of liability when only net interest was debited and the reversed amount was not separately claimed.

Market data charges recovered from Indian associated enterprises were not taxable as royalty under the India-USA DTAA, as the facts and legal position matched earlier Tribunal decisions and no distinction was established. The related addition was deleted. Reimbursements of salary and employee-related costs for seconded employees were likewise not treated as fees for included services or fees for technical services under the India-USA DTAA, following an earlier Tribunal ruling on comparable expense recoveries. The addition for employee-related reimbursements was deleted, while interest was to be levied consequentially in accordance with law.

Embedded profit, rather than the entire value of alleged bogus diamond purchases, is taxable where books of account remain accepted, stock and quantitative records show no adverse discrepancy, and corresponding sales are not disproved. Where accommodation bills cover goods actually sourced from other parties, the addition should be confined to the profit arising from that arrangement. A 3% profit estimate applies where no distinguishing material warrants a different estimate, including for later assessment years involving identical transaction facts.

Reassessment jurisdiction requires recorded reasons to show an independently formed prima facie belief and a rational, live nexus between investigation material and income alleged to have escaped assessment. Information understood as relating to bogus purchases cannot support an assessment of the same amounts as unexplained unsecured loans without transaction-specific application of mind; subsequent findings cannot cure defects in the recorded reasons. For unsecured loans, lender confirmations, banking records, tax documents and affidavits may discharge the initial burden on identity, transaction trail and source. A preceding equivalent bank credit alone does not establish an accommodation entry without verification and cogent rebuttal of the disclosed source.

Rule 11UA(2) permits an assessee issuing unquoted equity shares to choose either the Discounted Cash Flow or Net Asset Value method for determining fair market value under section 56(2)(viib). After a prescribed method is chosen, the Assessing Officer may scrutinise the valuation report but cannot replace it with a formula-based valuation merely because projections, management inputs, or standard disclaimers are questioned. Discounted Cash Flow projections cannot be rejected solely by comparison with subsequent performance. Rejection requires demonstrably incorrect data, a wholly erroneous basis, or a wrong valuation approach; absent such defects, the chosen method governs share-premium valuation.

Regulation 17(1) of the CBLR, 2018 requires a notice proposing revocation of a Customs Broker licence to be issued within ninety days of receipt of the offence report. Where no separate investigation report exists, Customs Act show-cause notices containing the investigation summary, allegations and relied-upon documents constitute the offence report. The limitation period cannot be deferred by later requesting documents already received. A notice issued after the mandatory period leaves no statutory authority to revoke the licence; the revocation was set aside and restoration of the licence directed.