Reasonable and bona fide cause under Section 273B protects an assessee from penalty for delayed furnishing of a tax audit report. The accountant's illness and medical treatment prevented timely preparation of accounts, while the audit report was furnished before scrutiny proceedings commenced. These circumstances support deletion of penalty imposed for delayed submission of the tax audit report under Section 271B.

Section 115BBE's enhanced 60% rate, effective from 1 April 2017, applies from assessment year 2018-19 and not to assessment year 2017-18. Unexplained money assessed under Section 69A for financial year 2016-17, corresponding to assessment year 2017-18, is taxable at the then-applicable 30% rate. The tax on the addition must therefore be computed at 30%, rather than 60%.

Reassessment proceedings cannot be validly initiated through a Section 148 notice issued in the name of a person who had died before its issuance. Section 159 permits continuation against a legal representative only where proceedings began during the deceased person's lifetime; where fresh proceedings are permissible after death, the jurisdictional notice must be issued to the legal representative. Revenue's lack of knowledge of the death, or a later assessment in the legal heir's name, does not cure the defect. Where the legal heir promptly objects and does not submit to jurisdiction, reassessment founded on the notice to the deceased is legally unsustainable.

A domestic company that validly exercised the section 115BAA option through Form No. 10-IC remains eligible for the 22% concessional tax rate in subsequent assessment years. Section 115BAA(5) gives continuing effect to an option exercised in the prescribed manner. Acknowledgement of the form, prior acceptance of the option, and disclosure in the relevant return establish compliance. Processing at the normal rate under section 143(1), or failure to produce supporting documents before the first appellate authority, does not nullify a subsisting statutory option demonstrated on record.

Penalty for concealment of income under Section 271(1)(c) remains sustainable where a survey detects a stock discrepancy omitted from the original return and the taxpayer discloses the resulting income only in a revised return. Admission that the original return was untrue or incomplete can establish concealment without further proof. A revised return filed after detection of undisclosed income under compulsion does not cure or erase the initial concealment. Binding High Court precedent supported sustaining the penalty.

Fee-based payment and settlement services operated on a non-profit basis to provide secure, efficient and cost-effective national payment infrastructure retained their charitable character where fees funded technology-intensive operations, surpluses were non-distributable, and the dominant purpose was advancing general public utility. Charging fees and earning incidental surplus did not trigger the proviso to Section 2(15), preserving exemption under Sections 11 and 12. Uniform access to payment facilities at identical charges did not amount to application of income for the benefit of promoter banks or other specified persons. Subscription to share capital alone did not establish such benefit, so no violation of Section 13(1)(c)(ii) read with Section 13(3) arose.

Business loss - commercial substance of related-party service arrangements - Interest on borrowed capital-commercial expediency of investment in another company - Disallowance of expenditure relating to exempt income - Unexplained share capital-genuineness of circular group-fund transactions Business loss - commercial substance of related-party service arrangements - Substance over form - Allowability of the claimed business loss where advisory-fee income and corresponding expenditure arose f... ... ...

Transfer pricing characterisation of service reseller - Reasoned departure from prior FAR characterisation - Characterisation of the assessee's purchase of services for resale as IT-enabled services without examining its functions or giving reasons for departure from the earlier characterisation HELD THAT: - The Dispute Resolution Panel affirmed the Transfer Pricing Officer's characterisation of the assessee as an IT-enabled service provider without cogent reasons and without consider... ... ...

Reassessment after scrutiny assessment - change of opinion - Limitation for reassessment notice following deemed notice under the amended reassessment regime Reassessment after scrutiny assessment - change of opinion - Reassessment of share-capital and investment transactions already examined in scrutiny assessment on the basis of an anonymous complaint - HELD THAT: - The original assessment had followed detailed enquiry into the petitioner's share-capital and investment transactions, wit... ... ...

Interest on delayed refunds under Vivad se Vishwas Scheme - CBDT Action Plan timeline for consequential orders after Form-5 Entitlement to interest on refund retained after issuance of Form-5 under the Vivad se Vishwas Act, 2020, and the date from which such interest is payable - HELD THAT: - Section 5(2) of the VsV Act and Rule 7 culminate in issuance of Form-5 and do not contemplate a further consequential order. Though Circular No. 03 of 2021 authorises the AO to pass a consequential order... ... ...

Limitation for penalty u/s 271DA for contravention of cash-receipt restrictions - Limitation for initiation of penalty proceedings under section 271DA for alleged receipt of cash in contravention of section 269ST - HELD THAT: - The two co-ordinate Bench decisions Shri. K. Umesh Shetty [2025 (1) TMI 1237 - KARNATAKA HIGH COURT] and Ganesh Agarwal [2026 (7) TMI 1035 - KARNATAKA HIGH COURT] adopted differing points for commencement of limitation under section 275(1)(c). The Court held that, on the ... ... ...

Opening stock valuation - Interest disallowance on undisputed outstanding credit Opening stock valuation - Closing stock carried forward as opening stock - Revaluation of the opening stock of Guar Dal where the corresponding closing stock of the preceding year had been accepted by the Department - HELD THAT: - The settled accounting principle is that the closing stock of an earlier year forms the opening stock of the succeeding year, the two assessments being interlinked for determination of ... ... ...

Reassessment based on loose paper - live link with assessee Whether reassessment notice founded on an unsigned and uncorroborated loose paper, without a live link between its contents and the assessee, was valid? - HELD THAT: - The loose paper neither identified the petitioner nor established any connection with the person named therein or with the entities referred to in the satisfaction note. The alleged rate and inference of escaped income were derived from third-party material and were ba... ... ...

Settlement under Section 125B of the Customs Act - writ petition which was pending before this Court against the order of the Settlement Commission has been decided by the Division Bench of this Court, vide its judgment [2017 (5) TMI 743 - DELHI HIGH COURT] and Hon'ble the Supreme Court has issued notices and stayed the effect and operation of the judgment [supra] HELD THAT:- We find that the present appeal was adjourned sine-die on 20.01.2016 and has thereafter has been listed on a number of... ... ...

Perverse findings based on an erroneous factual premise - Validity of the Tribunal's decision on limitation rendered on the premise that the assessee had adopted the Dispute Resolution Panel route - HELD THAT: - The assessee had admittedly pursued the appellate route before the Commissioner of Income Tax (Appeals), and not proceedings before the Dispute Resolution Panel. Since the Tribunal's discussion and conclusion proceeded throughout on the contrary factual foundation, its finding... ... ...

Adjustment of income-tax refund against outstanding demand - Release of the balance income-tax refund where adjustment against an outstanding demand is proposed - HELD THAT: - Where a refund is found due and adjustment under Section 245 of the Act of 1961 is proposed against an outstanding demand, only the amount proposed for withholding or adjustment may be retained. The remaining refund must be remitted immediately, without prejudice to the parties' right to contest whether the proposed ad... ... ...

Credit of tax deducted at source where deductor fails to deposit tax - Entitlement of a salaried taxpayer to credit of tax deducted at source by the employer but not deposited with the Revenue - HELD THAT: - Though the Revenue could have been justified in disallowing TDS not deposited by the deductor, the taxpayer could not be blamed for the employer's failure or deprived of the resulting legitimate entitlement as has been held by this Court in its judgement Satwant Singh Sanghera [2024 (10)... ... ...

Deduction for new industrial undertaking under section 80-IE - Recomputation of eligible profits under section 80-IA(10) - Excise-duty incentive as capital receipt - Working-partner remuneration and deduction computation Deduction for new industrial undertaking under section 80-IE - Splitting up or reconstruction of existing business - Transfer of previously used plant and machinery - Entitlement of the pharmaceutical manufacturing undertaking to deduction under section 80-IE despite the tran... ... ...

Faceless assessment - breach of natural justice - Writ jurisdiction despite alternative statutory remedy Faceless assessment - consideration of authenticated responses - Effective opportunity of personal hearing - Validity of the faceless assessment where authenticated replies were ignored, insufficient time was granted to answer the show-cause notice, and a meaningful personal hearing was not afforded - HELD THAT: - The replies filed in response to the notice under section 142(1) and the sho... ... ...

Interest on tax refund - effect of settlement under Kar Vivad Samadhan Scheme - Finality of unchallenged appellate directions HELD THAT:- The special leave petition was dismissed, with pending applications disposed of. No reason to interfere with the High Court's order.... ... ...