Commercially inseparable channel subscription and advertisement airtime distribution transactions should be aggregated for arm's-length benchmarking where they are mutually reinforcing, use the same assets, and operate under regulatory rights covering both revenue streams. Separate evaluation is unreliable when neither activity can practically be relinquished while retaining the other. Comparable entities must also have a similar functional and asset profile. Businesses involved in programme production, multi-channel broadcasting, radio operations, newspaper circulation, or ownership of significant intangibles are functionally dissimilar to a sports-channel and advertising-inventory distributor and should be excluded from the comparable set.

Revision of assessment under Section 263 requires an order to be both erroneous and prejudicial to the interests of the Revenue. Third-party search information, without incriminating or corroborative material linking an assessee to alleged cash payments, does not establish either requirement where the Assessing Officer has examined purchase records, allotment details and bank statements and accepted the explanation. Explanation 2(a) does not permit revision merely because different inquiries are preferred; it applies where necessary inquiries or verification were absent. Revision cannot authorise a fishing or roving inquiry or replace a plausible assessment view. The conditions for revision were therefore not established, rendering the revision invalid.

Receipts reflected in seized material and related bank deposits concerned an unregistered Samiti operated by three individuals and were attributable to an association of persons rather than to one individual. Additions in the individual assessment therefore could not be sustained. Any assessment of those receipts, if warranted, must be made in the association's assessment in accordance with law, with arithmetic errors in the seized-material workings addressed.

Taxable income from an alleged immovable-property sale requires evidence of actual receipt of consideration and completion of transfer. The asserted transaction remained disputed before a civil court, while bank records showed no credit to the assessee, possession remained inconsistent with a completed sale, and mortgaged title documents restricted transfer without lender consent. Reliance on departmental information without addressing this contrary evidence did not establish taxable consideration. The addition was deleted because only real income, rather than notional or unreal income from an uncompleted or unproven transfer, is taxable.

Registration under the Rajasthan Public Trust Act, 1959 is not an essential condition for a charitable institution's registration under Section 12AB of the Income-tax Act, 1961. Where a trust already holds valid Section 12AB registration and no contrary material is produced, the absence of State public-trust registration does not justify refusing approval under Section 80G. The trust's application for Section 80G approval is therefore required to be granted.

Registration application rejection for incompleteness, non-compliance with notices, and lack of material establishing genuine activities was set aside. Fresh consideration was directed following the applicant's request for another opportunity to comply, after allowing a reasonable opportunity to cure deficiencies and furnish required information. Costs were imposed for the earlier non-compliance, and the application was restored for a fresh decision.

Unexplained investment addition under Section 69 was sustained because the claimed cash advance from a proposed agricultural-land sale was unsupported during assessment. The receipt and agreement were first produced in appellate proceedings without explaining their earlier absence. As the sale did not materialise and the advance was repaid after five years, the claimed cash source remained unproved under the Section 292C presumption.

Best-judgment assessment requires a profit estimate that is fair, honest and reasonably connected with available material and circumstances. A net-profit rate of 6.5% of gross receipts was sustained because no books of account or credible contrary evidence were produced. The rate took account of past assessment history, comparative gross receipts and the reduction from the Assessing Officer's original 8% estimate.

An alleged on-money addition under Section 69 cannot be sustained solely on an unverified third-party excel sheet and statements where no reliable material links the taxpayer to a cash payment. The Revenue must corroborate such evidence through vouchers, receipts, ledgers, signed documents, comparable transactions, or other assessee-specific incriminating material. Denial of cross-examination of persons whose statements are relied on further undermines the evidentiary basis. Where the declared consideration exceeds stamp-duty valuation and the burden remains undischarged, the addition is unsustainable and must be deleted.

Rectification orders under Section 154 are appealable under Section 246A of the Income-tax Act, 1961. Rejecting an appeal by relying on Section 246, without examining the rectification claim or the taxpayer's claim for the concessional tax rate under Section 115BAB on merits, is unsustainable. Internal allocation of a faceless appeal to the JCIT(A) rather than the CIT(A) does not prejudice the taxpayer. The first appellate authority must adjudicate the rectification and concessional-rate claims on their merits in accordance with principles of natural justice.

Section 90(2) gives a non-resident the benefit of a more favourable Double Taxation Avoidance Agreement rate over domestic tax provisions. Section 206AA, which prescribes higher tax deduction where PAN is not furnished, operates procedurally and does not override that treaty protection. Accordingly, royalty and fees for technical services paid to non-residents may be subject to tax deduction at the applicable beneficial treaty rate despite the absence of PAN, rather than the higher domestic withholding rate.

GST levy on affiliation fees charged by an educational board for granting affiliation is under consideration. The challenge relies on a prior ruling that characterises affiliation as a statutory and regulatory function outside the scope of taxable supply or, alternatively, as exempt. No determination on taxability has been made. Notice was issued, and the respondents were given time to obtain instructions on the applicability of the prior ruling.

The 6 per cent schedule separately covers biodiesel other than biodiesel supplied for blending with High Speed Diesel and introduces renewable energy devices and their parts. For bundled supplies of these goods with the specified taxable service, deemed valuation applies: 70 per cent of gross consideration is treated as goods value and 30 per cent as service value. The 9 per cent schedule adds mineral ores and concentrates, plastic scrap, printed matter, and railway or tramway equipment, while the 14 per cent schedule adds specified carbonated fruit beverages.

The substituted Schedule entry for tariff heading 1209 covers seeds, fruit and spores of a kind used for sowing. An explanation confines the entry by excluding seeds intended for any use other than sowing, so coverage turns on intended use as sowing. Seeds meant for another purpose fall outside the entry. The revised Schedule treatment comes into force on 1 October 2021.

Goa GST reverse-charge treatment applies to supplies of specified essential oils other than citrus-fruit oils, including peppermint, spearmint, water-mint, horsemint and bergamot oils, when an unregistered person supplies them to a registered person. The supplier category is confined to unregistered persons and the recipient category covers registered persons, with the registered recipient bearing the tax obligation under the reverse-charge framework. The category takes effect on 1 October 2021.

State tax on specified COVID-19 medicines classified under Chapter 30 receives a partial exemption, limiting tax to nil for Tocilizumab and Amphotericin B, and to 2.5% for specified other medicines. The exemption applies only to named goods under the listed classification, exempts tax levied beyond the prescribed rate, and operates from 1 October 2021 through 31 December 2021, inclusive.

The rate entry is amended to cover unit-container food preparations intended for free distribution to economically weaker sections under government-approved programmes, and supplies of Fortified Rice Kernel (Premix) for ICDS or similar approved schemes. The corresponding entry in column (4) replaces "food preparations" with "goods". The changes apply from 1 October 2021.

Goa SGST exemption coverage is expanded to satellite launch services supplied by the Indian Space Research Organisation, Antrix Corporation Limited, or New Space India Limited. Such services are subject to nil central and State tax rates under the relevant exemption table. The exemption takes effect from 16 October 2020.

Government of Goa waives the portion of late fee payable for delayed furnishing of FORM GSTR-10 that exceeds two hundred and fifty rupees. The waiver applies to registered persons who failed to furnish the return by its due date but furnish FORM GSTR-10 between 22 September 2020 and 31 December 2020. Late fee remains payable up to the stated cap.

Time limit for furnishing FORM GSTR-8 for December 2024 is extended until 12 January 2025 for statements reporting outward supplies of goods or services or both effected through e-commerce operators. The extension applies only to the December 2024 statement, operates with the prescribed GSTR-8 filing procedure, and is deemed effective from 10 January 2025.