Educational exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 requires an institution to exist solely for educational purposes and not for profit. A surplus alone does not establish a profit motive; the institution's objects and use of income are relevant. Substantial government financing is assessed by considering annual and capital grants alongside government support in kind, including land and infrastructure. Under Rule 46A of the Income-tax Rules, an assessing officer was given an opportunity to respond to additional evidence through a remand report request and reminders. No report was submitted, and no impropriety in admitting the evidence was substantiated.

Tax collection at source under Section 206C(1C) of the Income-tax Act, 1961 does not apply to compounding fees collected from persons engaged in illegal mining or transportation without a lease or licence. The provision requires a lease, licence, contract or transfer of a right or interest in a mine or quarry. Compounding payments for offences are penal and distinct from royalty under lawful mining arrangements. Related tax demands, interest and consequential penalties cannot be sustained. Judicial discipline requires adherence to a coordinate-bench decision addressing the same statutory provisions and receipts.

Revision of a block assessment under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Revenue loss alone or disagreement with a permissible view taken by the Assessing Officer does not justify revision. Alleged non-consideration of seized entries relating to cash loans and interest cannot support revision unless both statutory conditions are met.

GST appeals filed within the extension scheme's permitted period cannot be rejected as time-barred solely because the appeal does not expressly invoke the scheme or because of a pre-deposit shortfall without an opportunity to cure it. The scheme permitted appeals until 31 January 2024, subject to payment conditions including a 12.5% pre-deposit. An appeal filed within that period with a 10% pre-deposit had a curable shortfall, which was subsequently paid. Consideration on merits remains conditional on compliance with the scheme.

Before rejecting an appeal as time-barred, the appellate authority must consider eligibility under a potentially applicable extension notification and allow an opportunity to cure a shortfall in the additional pre-deposit. The extension covers appeals against assessment orders passed on or before 31 January 2023 and filed by 31 January 2024, subject to an additional deposit of 2.5% of disputed tax over the mandatory 10% pre-deposit. Where eligibility was not considered, it remains subject to fresh determination.

Proposed E-Way Bill numbering changes would increase the E-Way Bill number from 12 to 14 digits and the Consolidated E-Way Bill number from 10 to 11 digits, with effect from 1 January 2027. Taxpayers, GSPs, ERP and software providers, and API integrators are advised to modify applications, APIs, database schemas and validation rules to accommodate the revised formats. The changes are to be released in the Sandbox environment for testing, with relevant details to be published on the E-Way Bill Portal.

Digital onboarding and re-KYC are permitted for individual persons resident outside India, including non-resident Indians, Overseas Citizens of India and foreign nationals, when they are located in a Financial Action Task Force (FATF)-compliant country. Intermediaries may rely on another SEBI-registered intermediary's KYC through KRA records or another financial-sector-regulated entity's KYC through CKYCRR records, but retain ultimate KYC responsibility. In-person verification is required, with video verification used where physical verification is not feasible. Intermediaries must comply with the applicable cybersecurity framework and provide completed KYC information to the KRA within three working days.

In the second phase on 3 November 2026, 114 parcels attracted successful bids totalling Rs.218 crore against an aggregate reserve price of Rs.184.81 crore, a premium of 17.96%. Across both phases, 264 parcels attracted Rs.584.33 crore in successful bids against a combined reserve price of Rs.497.29 crore, a 17.50% premium. NLMC plans a third round for the remaining unsold parcels, subject to applicable approvals and conditions; its schedule and other details are to be announced in due course.

The assessment-year coverage of the Andhra Pradesh Electricity Regulatory Commission, Hyderabad, notified under section 10(46) of the Income-tax Act, 1961, is corrected in the English version of the 2019 notification. Under section 536 of the Income Tax Act, 2025, the stated period changes from assessment years 2019-2020 through 2023-2024 to assessment years 2020-2021 through 2024-2025. The Hindi version of the 2019 notification remains unchanged.

For the purposes of the relevant subsection of section 206 of the Income Tax Act, 2025, Adjudicating Authority has the meaning assigned under section 5(1) of the Insolvency and Bankruptcy Code, 2016. For the purposes of the relevant clause in the Explanation to section 115JB of the Income Tax Act, 1961, the same term has that meaning. Both provisions therefore use the definition from the Insolvency and Bankruptcy Code for their respective purposes.

Discount or interest on deep discount bonds and business debentures is deductible proportionately on accrual for the relevant accounting year, even though payment is due at maturity. The contractual liability arises when the instruments are issued, while the borrowing provides a business benefit over their term. Accrual accounting and the matching principle allocate the expenditure across that period, permitting deduction of the portion attributable to each accounting year.

Documents found during a survey attract a rebuttable presumption under section 292C of the Income-tax Act, 1961 concerning their ownership and the truth of their contents. The assessee bears the burden of rebutting that presumption. A receipt figure matching the accounts can corroborate recorded actual receipts, and an addition for unaccounted receipts may be based on survey evidence rather than solely on a survey statement. An unrebutted presumption concerning the document may support the addition.

Silver mixed with palladium alloy is taxable as silver bullion under the applicable notification. Palladium is costlier than silver, distinguishing the mixture from inferior alloys and supporting its classification as silver bullion for tax purposes. This treatment is in favour of the assessee, and no question of law arises.

Central excise tax effect is approximately Rs. 5 lakh. An existing central excise precedent applies against the Revenue.

Survey statements alone cannot support an addition for suppressed receipts, although independently gathered survey material may be assessed on its merits. Cash purchases of emergency medicines and surgical disposables may qualify for deduction despite exceeding the statutory cash-payment threshold where cash payment is a compulsion of normal practice and the purchaser has no other choice. Maintenance payments forming part of a tenancy arrangement may be taxable in the assessee's hands even if paid to the assessee's father, particularly where claimed maintenance expenditure is unsubstantiated.

Disallowance of a bona fide deduction claim supported by a legitimate basis does not, by itself, justify a penalty for furnishing inaccurate particulars. A managerial service fee deduction claimed in the year corresponding income was received had a legitimate basis where an earlier assessment permitted the expenditure to be claimed in that year and the record supported the claim's bona fides.

Central excise was the subject of a civil appeal in which no ground was found to interfere with the impugned order. The appeal was dismissed.

Section 14A and Rule 8D address expenditure attributable to income excluded from total income. No disallowance under Section 14A can be made where no exempt income is earned during the relevant year. The restriction is intended to prevent a taxpayer from obtaining both exempt income and a deduction for expenditure related to that income.

Disputed diamond purchases may be subject to an estimated addition of 6% for possible revenue leakage where purchase invoices, payment details, stock records and sales records attract no adverse findings, consistent with jurisdictional precedent and treatment of similar accommodation-entry purchases. Information from a third-party investigation into accommodation entries can support a belief that income escaped assessment, particularly where verification of the purchases in the original assessment has not been established, rather than constituting a mere change of opinion. Prior approval under section 153D applies to assessments under section 153A or 153C, not reassessments completed under section 143(3) read with section 147.

Capital gains on land converted into stock-in-trade are taxable proportionately when the converted stock is sold or transferred. Under sections 45(2) and 48 of the Income-tax Act, 1961, the fair market value on the conversion date is used as consideration for computing the gains. Stamp-duty value cannot replace that fair market value. Valuation may be determined through a valuation-cell reference or evidence of contemporaneous registrations, with closing stock recomputed accordingly.