In a concluded assessment, additions under Section 153A require incriminating material found during search. Board resolutions, legal notes, valuation reports and related records concerning a firm's conversion, constitution and prior transactions do not meet that requirement where they disclose no undisclosed income; additions founded on them lack legal basis. Tax-neutral succession under Section 47(xiii) remains available where the business assets and liabilities existing immediately before succession vest unchanged in the company and partners receive only shares reflecting their pre-succession interests. Asset sales and changes in capital-sharing ratios before succession do not, by themselves, breach those conditions or justify denial of the Section 80-IA deduction.

Uncorroborated loose sheets containing scribbled figures cannot, by themselves, support an addition for undisclosed consideration in a property purchase. In a search assessment, such sheets are not books of account and require corroborative incriminating material. Without evidence of cash payment or of the availability and deployment of funds beyond the consideration recorded in the registered sale deed, the addition is unsustainable.

Section 148A(b) required that the assessee receive 30 days to respond before reassessment action. Curtailing that period to 15 days despite a timely extension request, when sufficient time remained for consideration, prejudiced the assessee's right to be heard. A reply uploaded before the Section 148A(d) order but not considered violated principles of natural justice. The Section 148A(d) order and consequential Section 148 notice were set aside, requiring a fresh decision after considering the reply in accordance with law.

Reassessment after a completed scrutiny assessment cannot revisit the existence of a permanent establishment where the issue was specifically examined, the taxpayer furnished detailed replies, and reopening relies on the same material. The absence of an express finding in the assessment order does not permit correction of an Assessing Officer's omission; such reopening constitutes a change of opinion and undermines assessment finality. Beyond four years, reassessment requires income escapement caused by failure to make full and true disclosure. Where subscription receipts and the Indian agent's role were disclosed during scrutiny, that condition is absent, and a notice issued after the applicable limitation period is time-barred.

Section 69 applies where investments are unrecorded in the books and the assessee fails to satisfactorily explain their nature and source; Section 115BBE governs the tax treatment of income assessed under that provision. Investments, loans and advances disclosed in the books and substantiated by bank records and audited financial statements, including brought-forward balances, do not support additions as unexplained investments. The Tribunal's factual assessment of those materials disclosed neither perversity nor illegality, so deletion of the additions did not give rise to a substantial question of law.

Recall of the writ proceeding was allowed. The revived petition was then closed, but the closure did not prevent institution of fresh proceedings on the same cause of action. Fresh proceedings may be instituted on that cause of action and may include a challenge to Section 147A. Existing protection was continued for 90 days.

Reassessment proceedings may be challenged afresh where a statutory amendment alters the basis for assessing-officer jurisdiction. Following the Supreme Court's remand approach, the earlier judgment was recalled and the writ petition was closed with liberty to initiate fresh proceedings on the same cause of action, including a challenge to Section 147A and consequential reliefs. Interim protection was continued for 90 days, but would cease if fresh proceedings were not commenced within that period.

Reassessment challenges concerning the validity of orders under section 148A(d) and notices under section 148, including alleged defects in sanction or approval under section 151, were remitted for fresh consideration after the Supreme Court set aside earlier High Court judgments on a limited ground arising from a subsequent statutory amendment. The earlier judgment was recalled, the writ petition was closed with liberty to file a fresh petition on the same cause of action, including a challenge to section 147A, and existing interim protection continued for 90 days.

Condonation of delayed returns seeking the Section 80P deduction is governed by the specific CBDT scheme for cooperative societies, rather than general guidance concerning delayed refund or loss claims. The specific scheme requires consideration of circumstances beyond the taxpayer's control, including delays in statutory audit, and whether genuine hardship arose. Delayed receipt of an audit report through the State Audit Department during COVID-19 restrictions, followed by an explained short filing delay, supports a liberal rather than hypertechnical approach to condonation. Once delay is condoned, the delayed return may be considered for the Section 80P deduction in accordance with law.

Employee Stock Option Scheme expenditure may be debited to the profit and loss account as allowable revenue expenditure. For Financial Year 2017-18, a share valuation report issued by a Chartered Accountant cannot be rejected under a later requirement for Merchant Banker certification, because that requirement applied only from the subsequent financial year. Consequently, an addition under Section 56(2)(viib) based solely on the absence of Merchant Banker certification is unsustainable for the relevant year.

Input tax credit on GST paid for land-survey charges incurred to acquire land surrendered for afforestation is unavailable. Survey services for alternate land surrendered to the Forest Department lack the required nexus with business because that land neither remained with the taxpayer nor generated taxable outward supplies. Survey services relating to golf-course land are preliminary services directly connected with construction or development of immovable property on own account and fall within blocked credit for such construction. Services relating to alternate land surrendered and written off are also treated as blocked credit for goods or services written off. Land transactions are outside the scope of supply.

Specialised laboratory-based sex sorting of bovine semen is classified under SAC 998349 as other technical and scientific services, rather than under SAC 9986 for support services to agriculture, forestry, fishing and animal husbandry. The intermediate-production-process coverage in Heading 9986 applies only to job work related to rearing life forms; laboratory separation of X- and Y-bearing sperm does not directly involve livestock rearing or animal-husbandry activities. Services under Heading 9983 are taxable at 18% GST and receive no exemption. The classification therefore treats semen sorting as a residuary technical and scientific service.

Weekly-market fee collection rights leased by a Town Panchayat to a tender contractor remain activities connected with the Panchayat function of markets and fairs where the Panchayat prescribes fees, issues receipts in its name, and retains control. Outsourcing collection for operational convenience does not convert that public-authority function into an independent commercial activity. As an activity undertaken by a local authority in relation to a function entrusted to Panchayats under Article 243G, the arrangement is treated as neither a supply of goods nor a supply of services under the GST framework and is therefore outside GST.

Aerator gear boxes fall under HSN 84834000 as gear boxes and other speed changers, attracting 18% GST rather than the concessional rate for specified machinery and parts under Heading 8436. Their use in aquaculture aerators does not override the specific tariff description, and Heading 8436 contains no relevant aquaculture or prawn-rearing machinery entry. Separately supplied bevel and helical gears, pinions, worm shafts and worm wheels fall under HSN 84839000 as separately presented toothed wheels or transmission elements. They also attract 18% GST and cannot obtain the Heading 8436 concession.

Exhaustion of the statutory appellate remedy under GST precluded direct writ review of an assessment demand and rejection of a rectification application. High Court declined to entertain the writ petition because the GST appellate mechanism provided an available appeal. The petition was disposed of with liberty to file a statutory appeal within 30 days; the appeal must be entertained without a limitation objection and decided on merits, with all contentions remaining open.

GST-related tax-default allegations already subject to proceedings under the special GST enactments must be investigated and addressed through the procedure prescribed by those enactments. The Bharatiya Nagarik Suraksha Sanhita requires offences governed by a special law to be dealt with under that law, giving the GST statutory framework priority over general criminal-law recourse. On that basis, Bharatiya Nyaya Sanhita proceedings for the same alleged GST default were impermissible against the applicant, and the charge sheet and cognizance order were set aside to that extent.

Section 74 CGST adjudication requires an effective opportunity to respond where GST registration has been cancelled and a revised correspondence address has been communicated. Adjudication founded solely on the absence of a reply cannot be sustained without procedural fairness and a meaningful right to be heard. Voluntary reversal of allegedly excess input tax credit before initiation of proceedings also requires an opportunity to contest the continuation and characterisation of proceedings. The merits of the show-cause proceedings, including whether Section 74 or Section 73 applies, remain unresolved.

Differential GST liability arising from the transition from VAT to GST under works contracts depends on the terms and conditions of each individual contract. Where contracts involve different parties and contractual arrangements, reimbursement obligations cannot be determined through uniform directions. Statutory tax authorities also cannot be directed to refrain from exercising powers contrary to the GST framework. Blanket directions requiring reimbursement of differential tax liability and restraining tax enforcement are therefore impermissible without a contract-specific determination.

Rule 26(3) requires GST adjudication orders issued electronically to bear a digital signature certificate, e-signature, or another notified verification mode, establishing authorship and accountability. Absence of a physical or electronic signature on the detailed adjudication order is a substantive failure, not a curable mistake, defect or omission. A signed DRC-07 cannot validate or cure the unsigned detailed order; the unsigned order is invalid.

Partial rejection of refund claims for unutilised input tax credit under Section 54(3), without affording an opportunity of hearing or recording reasons for the rejected portion, breaches the principles of natural justice and the obligation to issue a reasoned decision. Such procedural deficiencies render the partial rejection invalid, as affected claimants must be heard and given reasons enabling them to understand and challenge the basis of the decision.