Search-related penalty under section 271AAB displaces section 271(1)(c) only for undisclosed income of a statutorily defined specified previous year. Where a search occurred on 04.02.2016, only assessment year 2016-17 qualified; penalty under section 271(1)(c) for that year was void, while section 271(1)(c) remained potentially applicable to earlier years. For assessment years 2010-11 to 2015-16, additions of deemed annual letting value based on disallowed vacancy allowance could not support penalty where property details and actual rent were fully disclosed. Rejection of a claim, without false, incorrect, or incomplete particulars, does not establish concealment or furnishing inaccurate particulars. Penalties for all years were therefore unsustainable.

Loss arising from market-value fluctuation of securities classified as Available for Sale and held in the course of banking business is allowable as a revenue loss. Securities acquired under banking norms require valuation at market price, and the difference between book value and market value arises in the ordinary course of that business. Accordingly, the valuation loss is deductible as a revenue loss and the disallowance is deleted.

Late-filing fee under section 234E could not be computed while processing TDS statements under section 200A for periods before 1 June 2015. The amendment expressly enabling such computation under section 200A operated prospectively from that date. Where no jurisdictional High Court ruling existed and High Courts had adopted divergent interpretations, the construction favourable to the assessee applied. Consequently, late-filing fee levied through pre-amendment section 200A processing, along with the consequential demand, was liable to be deleted.

Cash deposits recorded in regularly maintained and audited books, supported by cash-book entries and corresponding VAT-return sales, were not treated as wholly unexplained where no defect in the books was identified and the books were not rejected. Statistical comparison showing abnormal cash-sales trends against an earlier period alone did not support the full proposed addition. Possible revenue leakage was addressed through a lump-sum addition, restricted to Rs. 5 lakh and taxable as normal business income.

Customer advances relating to completed real-estate projects should not be taxed again where revenue was consistently recognised on execution of sale deeds and had already been offered to tax in earlier years. Section 43CB, effective from 1 April 2017, does not apply to projects commenced before 2011. Subject to verification that revenue from the relevant projects was previously taxed, adding outstanding customer advances would constitute impermissible double taxation and the addition should be deleted.

Unsecured loans from identified corporate lenders were satisfactorily explained under Section 68 where confirmations, tax returns, bank statements, ledger extracts and audited financial statements established identity, creditworthiness and genuineness. Banking-channel transactions without cash deposits, coupled with no material linking the loans to the assessee's unaccounted funds, shifted the burden to the Assessing Officer; suspicion, alleged accommodation entries or lack of business activity could not sustain additions. The assessee need not prove the source of the source. Share-sale receipts from directors were likewise explained through documented fund flow from an identified company and were not liable to addition as unexplained cash credits.

Charitable trusts that held earlier exemption and timely sought fresh registration under the new registration regime within the extended CBDT deadline remain eligible for exemption for the relevant assessment year. Where registration is granted after the application is found in order, making the certificate operative only from the succeeding year would create an anomalous gap between exempt earlier and later years. Registration should therefore operate from the relevant assessment year, requiring allowance of exemption and deduction under Section 11.

Charitable trusts registered under section 12AA may claim exemption under section 11 where the return is validly filed within the time permitted by section 139, including a belated return filed under section 139(4). The CBDT clarification treats the expression "within the time allowed under section 139" as broader than the due date for filing under section 139(1). On materially similar facts, the claimed section 11 exemption was required to be allowed for AY 2018-19.

Securities held by a banking institution as stock-in-trade do not attract disallowance of expenditure relating to exempt income in the stated circumstances. Tax deducted at source credit on recoveries from auction sale of defaulting borrowers' properties remains available where the related interest and other recoveries are offered to tax, even if the balance sale proceeds are credited to borrowers' accounts. Brought-forward long-term capital losses may be carried forward where preceding scrutiny assessments allowed those losses and contain no specific disallowance. The expenditure disallowance, denial of tax credit, and denial of loss carry-forward were therefore not sustainable.

Third-party seized documents cannot alone support additions where no statement from their possessor establishes their nature, authorship or contents, departmental inquiry yields no adverse material, and no independent corroboration links them to the assessee; the additions are unsustainable. Statutory approval for assessment must reflect independent application of mind to each assessment year. A single omnibus approval covering multiple years, issued mechanically, fails that requirement and vitiates the assessment. Consequently, assessments based on both defective consolidated approval and unsupported third-party material cannot be sustained.

Reassessment notices under Section 148 in cases assigned to Central Charges must be issued through automated allocation under the faceless mechanism prescribed by Sections 144B and 151A and the e-Assessment of Income Escaping Assessment Scheme, 2022. The exclusion for assessment orders in Central Charges does not extend to the issuance of reassessment notices. Section 124(3) limits objections to territorial jurisdiction and does not bar a challenge to an Assessing Officer's inherent statutory lack of authority. Such jurisdiction cannot arise through acquiescence, waiver, or delayed objection. Notices issued outside the mandatory faceless mechanism are invalid, and reassessment orders based on them are void.

Reassessment proceedings may be initiated by the jurisdictional Assessing Officer notwithstanding the faceless assessment scheme. Binding precedent recognised concurrent competence of the jurisdictional Assessing Officer and the faceless Assessment Officer to commence reassessment, and subsequent decisions had rejected the same challenge. As the governing precedent remained unstayed, reassessment initiation by the jurisdictional Assessing Officer was treated as valid, with the issue resolved against the assessee.

UCO Bank has launched an International Financial Services Centre Banking Unit at GIFT City to provide permitted international banking services. The unit offers trade finance, external commercial borrowings, foreign-currency loans, loan syndication, treasury services and other permitted financial services. It serves Indian corporates, exporters, importers, financial institutions, overseas businesses and other eligible customers requiring cross-border financing and access to global financial markets. FCNR(B) deposits are also offered through the unit.

Registered persons within the prescribed aggregate-turnover threshold must follow a special quarterly FORM GSTR-1 procedure. Details of outward supplies for October-December 2020 are due by 13 January 2021, and those for January-March 2021 are due by 13 April 2021. The time limit for furnishing details or returns for October 2020 through March 2021 is to be specified subsequently through publication in the Official Gazette.

Banking-sector participation is emphasised through last-mile credit access for MSMEs, women entrepreneurs, rural artisans, small farmers and other underserved beneficiaries. Banks are urged to expedite government-scheme applications, maximise coverage and use technology for timely financial support. Industrial-policy assistance and incentives cover startups, SC/ST entrepreneurs, persons with disabilities and first-generation entrepreneurs. Greater coordination, expanded village banking access, and vigilance against cyber fraud and mule accounts are also prioritised.

Designation-based substitution is made in orders under the Telangana Goods and Services Tax Act, 2017. The entry naming the Chief Commissioner of Hyderabad Zone is replaced by the Chief Commissioner of Central Tax Hyderabad Zone. The entry naming the Commissioner of State Tax is replaced by the Commissioner of State Tax, Office of Commissioner of Commercial Taxes, Telangana State, Hyderabad. The amendment identifies relevant positions by official designation rather than individual officeholders.

Historical-scenario stress testing for commodity derivatives now caps extreme peak historical price movements at the level corresponding to a Z-score of 5, replacing the previous Z-score threshold of 10. The cap applies to maximum percentage price rises and falls over the applicable margin period of risk, using the mean and standard deviation of returns across the preceding 15 years for Z-score calculation. Recognised clearing corporations with commodity derivatives segments must apply the revised stress-testing parameter with immediate effect.

Government departments, governmental societies and agencies engaging contractors or suppliers must obtain GST registration as tax deductors if unregistered. They must deduct GST TDS at 2% on contracts and government supplies exceeding the prescribed threshold and file Form GSTR-7 online by the 10th of the following month. For contracts below the TDS threshold, departments must submit prescribed details to the Commissioner of Taxes. Future contracts may be awarded to contractors or suppliers only upon submission of a Tax Clearance Certificate confirming payment of prior tax dues. Officers may be held personally liable for omissions or commissions causing revenue loss.

Draft SOP requires NBFC Factors to use the specified SWIFT message text when remitting foreign-currency factoring proceeds to AD-I Banks, so those banks do not create Inward Remittance Messages (IRMs) for such receipts. Where Factors discount export bills and release INR funds, customers seeking IRMs must approach the Factors rather than AD-I Banks. Factoring agencies must correctly identify factoring-related transactions when remitting funds. Exporters will be able to view NBFC Factor-related IRMs on the DGFT portal and self-certify eBRCs by matching remittances with invoices or Shipping Bills. Stakeholder comments are invited within 30 days of publication.

E-invoicing applicability under rule 48(4) of the Telangana Goods and Services Tax Rules, 2017 is expanded by reducing the aggregate-turnover threshold in the existing notification from five hundred crore rupees to one hundred crore rupees, with effect from 1 January 2021. The amendment is deemed effective from 10 November 2020.