Employees' ESIC and provident fund contributions deposited after the due date prescribed under the relevant welfare statutes are not deductible. Sections 36(1)(va), 2(24)(x) and 43B distinguish employees' contributions from employer contributions: delayed employee deposits remain taxable and cannot be allowed merely through the provisions applicable to employer payments. The disallowance of delayed employees' ESIC/PF contributions was therefore sustained, against the assessee and in favour of Revenue.

Section 68 requires a satisfactory explanation for cash deposits, but available evidence should not be wholly disregarded where it partly substantiates the source; the unexplained-credit addition was therefore restricted. Section 115BBE applied only to transactions occurring on or after 1 April 2017 and did not apply to earlier transactions. Where the return was late and books were unaudited, net business profit could be estimated at 8% of accepted turnover, so that addition remained sustained.

Development agreements already filed and examined during assessment are not additional evidence for appellate purposes, so Rule 46A does not require a remand report. A partner signing such an agreement solely as managing partner for a partnership firm acts in a representative capacity. Where the firm is the developer and contracting party, neither a property transfer nor income arises to the partner individually merely from that signature. Any tax liability arising from the agreement attaches to the contracting entity rather than the individual partner.

Section 40(a)(ia) does not disallow expenditure merely because tax was deducted at a lower rate under a different TDS provision where the dispute concerns the characterisation of payments and no default finding exists under section 201. Any shortfall in tax deduction is addressed through default proceedings rather than expense disallowance. Rejection of audited books under section 145(3) requires specific defects establishing that the accounts are unreliable. Cash payments below the prescribed threshold and unavailable bills, when adequately explained and supported, do not alone justify rejecting accounts. Estimated net-profit additions require meaningful opportunity and must account for changed commercial arrangements affecting margins and indirect costs.

Assessment and first appellate proceedings conducted without effective compliance by the assessee resulted in ex parte additions and disallowances. The need to provide a reasonable opportunity of hearing required remand of the assessment for de novo adjudication. The Assessing Officer must permit the assessee to present its case and make a fresh determination after granting that opportunity.

Section 153D requires prior approval for each assessment year before an assessment under sections 153A and 143(3) is completed. Approval received after the assessment order is passed does not satisfy the prior-approval requirement. A consolidated approval covering several years must also demonstrate independent application of mind to each draft assessment order and the relevant material; a bare statement approving the drafts does not establish that consideration. Absence of timely, reasoned, year-specific approval renders the assessment invalid.

Parallel substantive additions for the same alleged undisclosed share-capital income were unjustified where the connected entity had already been assessed as the ultimate beneficiary of those funds. Once deletion of the corresponding addition in that entity's assessment attained finality, the duplicate substantive addition in the assessee's hands could not stand. The assessee's deletion was consequently sustained.

Receipts and interest appearing in Form 26AS under an erstwhile PAN surrendered on amalgamation should not be added again where reconciliation establishes their inclusion in income reported under the surviving PAN. In reassessment, the critical inquiry is whether the Form 26AS entries form part of the aggregate contract receipts and interest already offered to tax. Where that reconciliation remains uncontroverted, a further addition duplicates income and results in impermissible double taxation.

Completed or unabated assessments under Section 153A require incriminating material found during a search before additions may be made. Where original returns had attained finality because no notice under Section 143(2) was issued within the prescribed period and no assessment or reassessment was pending on the search date, additions cannot rest solely on material already available on record. In the absence of seized material concerning unexplained unsecured loans, related interest expenditure, or delayed employee PF/ESI contributions, reassessment under Section 153A is not permissible and such additions are unsustainable.

Estimated assessment applying an 8% net-profit rate to gross receipts, including scrap sales, requires reconsideration where books were rejected for audit non-compliance without adequate consideration of prior gross-profit and net-profit results, depreciation, and the proper treatment of scrap-sale receipts. The appellate order was set aside for a fresh assessment after reasonable opportunity, requiring these factors to be addressed in determining taxable profit.

Reassessment beyond four years after an assessment under Section 143(3) requires income to have escaped assessment because of the assessee's failure to file a return or to disclose fully and truly all material facts. Recorded reasons must allege that failure. Where information on capital additions, asset acquisition and partners' withdrawals was already on the assessment record, an assertion that it was not verified does not satisfy this jurisdictional condition. Reassessment initiated without the required allegation or failure is invalid and liable to be quashed.

For admitted contract receipts whose character, source and genuineness are undisputed, profit estimation at 50% lacks a reasonable basis; the 8% presumptive-tax benchmark under section 44AD provides a fair basis in the stated circumstances. Business income is consequently recomputed at 8% of gross contract receipts. A concealment penalty under section 271(1)(c) does not survive where the addition rests solely on estimated profit, first-year operations and an internal management dispute explain non-filing and non-compliance, and tax deducted at source leaves no substantial revenue loss after recomputation.

Penalty for concealment of income or furnishing inaccurate particulars cannot be sustained solely on an estimated profit addition from alleged non-genuine purchases without material independently establishing concealment or inaccurate particulars. Proceedings initiated and levied under the concealment limb do not involve a charge mismatch merely because cancellation was sought on that basis. Deletion of penalty remains justified where the addition represents only an estimated profit element and does not establish culpable conduct. Penalty proceedings linked to organised tax-evasion activity fall within the CBDT circular exception permitting Revenue appeals irrespective of the prescribed monetary limit.

Reliance on adverse third-party statements requires disclosure and an effective opportunity for cross-examination; otherwise, it breaches principles of natural justice. Documented listed-share sale proceeds, supported by banking records, demat credits, recognised-exchange trades and registered-broker transactions, cannot be characterised as unexplained cash credit where that evidence remains unrebutted. General investigation material, abnormal price movement or suspicious counterparties do not establish accommodation entries without a proven nexus, collusion, cash trail or price-manipulation role of the assessee. The human-probabilities test cannot displace direct documentary evidence without cogent corroboration, and a consequential alleged-commission addition cannot survive.

External development charges paid to HUDA for statutory development works do not constitute rent for tax deduction at source under Section 194-I. A demand treating the payer as an assessee in default under Sections 201(1) and 201(1A) cannot therefore be sustained on a rental-payment basis. Examination of liability under Section 194C is not warranted where the original demand was founded exclusively on Section 194-I rather than contractual-work payments.

Refund of accumulated input tax credit for supplier invoices is restricted to credit supported by details uploaded in FORM GSTR-1 and reflected in FORM GSTR-2A. This replaces the earlier treatment of invoices absent from FORM GSTR-2A where invoice copies could be uploaded with the refund application. The restriction does not apply to ITC relating to imports, Input Service Distributor invoices, or inward supplies subject to the reverse charge mechanism. Refund treatment for these categories continues on the pre-existing basis.

Pre-CIRP GST dues constitute operational debt, to be claimed before the NCLT, and coercive recovery cannot proceed during the IBC moratorium. Existing GST registration should not be cancelled, while a corporate debtor under CIRP must obtain fresh registration in each previously registered State or Union territory. The IRP/RP is responsible for post-insolvency GST compliance and the first return. Transitional input tax credit may be claimed on qualifying post-appointment supplies invoiced to the erstwhile GSTIN, subject to applicable conditions and specified exceptions.

Personal-search safeguards under Section 50 of the NDPS Act require that a person be informed of the right to be searched before a Gazetted Officer or Magistrate. Prima facie non-compliance arose because the search panchnama, complaint, and witness statements did not record this information, while the purported notice conflicted with contemporaneous records, lacked panch signatures, and appeared to be an afterthought. Together with the absence of antecedents, these circumstances supported bail subject to conditions.

Share-capital additions under Section 68 require evidence beyond a retracted search statement, which cannot independently justify an addition without a nexus to incriminating search material. Documentary proof of investors' identity, creditworthiness and genuineness supported deletion of specified additions, while the identified unexplained credit remained taxable. Investments examined in a settlement order were conclusively covered under Section 245I. Share-premium valuation under Section 56(2)(viib) must follow Rule 11UA(2): an undisputed NAV or discounted cash-flow valuation cannot be rejected merely for an alternative view of share value. Accordingly, the share-premium additions were deleted.

Goa GST return non-filer procedure requires a notice in FORM GSTR-3A, allowing fifteen days to furnish the return. Continued non-filing of returns under sections 39 or 45 permits best judgment assessment under section 62 without a separate assessment notice. The proper officer may use return data, auto-populated supply details, e-way bill information, inspection material, and other available information to issue FORM GST ASMT-13. A valid return filed within thirty days of service of the assessment order results in deemed withdrawal; continued default may trigger recovery and registration cancellation.