Interest paid by a co-operative bank to co-operative housing societies on time deposits is subject to tax deduction at source where it exceeds the prescribed threshold. The specific rules applicable to co-operative societies carrying on banking business prevail over the general member-interest exemption. The amendment effective from 1 June 2015 excludes co-operative banks from that exemption for time-deposit interest, operates prospectively, and applies to the relevant assessment year. Housing co-operative society recipients are not banking entities eligible for the exemption; accordingly, the bank must deduct tax on qualifying interest payments.

Accommodation-entry assessments distinguish between unidentified and identified beneficiaries: related bank credits are assessable as unexplained cash credits where beneficiaries are not disclosed, while commission-rate assessment applies where they are identified. The estimated commission-income additions therefore require fresh determination under that principle, as genuine trading and the claimed commission rate were unsupported. Share application money remains taxable as unexplained cash credit where confirmations do not establish subscribers' identity, financial capacity and transaction genuineness. Cash deposits remain undisclosed income where no documentary evidence establishes their source.

Revisional jurisdiction requires an assessment order to be both erroneous and prejudicial to the interests of the Revenue. Explanation 2 to section 263 applies where the Assessing Officer has failed to make necessary inquiry or verification. Where the assessment record shows a specific inquiry into a section 80G claim, supported by furnished particulars and documents, revision cannot rest on alleged lack of inquiry. Corporate social responsibility expenditure disallowed under section 37(1) may still raise a debatable issue regarding eligibility for section 80G deduction. An assessment adopting a plausible view on that issue is not erroneous, making revision under section 263 impermissible.

Tax deduction at source is not required on interest paid by a co-operative bank to a co-operative-society depositor, as the exemption for interest paid by one co-operative society to another continues to apply to co-operative banks in respect of time deposits. Consequently, the bank cannot be treated as an assessee in default for non-deduction on such interest. Late fee for delayed TDS statements depends on whether the relevant return was filed within the prescribed time; verification of timely filing is required, and the fee must be deleted if timely filing is established.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the Revenue. Where the taxpayer disclosed CSR payments and supporting donation particulars, acceptance of a deduction claim under section 80G may represent a considered and legally plausible view. A different view does not establish error when two reasonable views are possible, and inadequate inquiry differs from complete absence of inquiry. Disallowance of CSR expenditure as business expenditure under section 37(1) does not prevent a separate section 80G deduction if its conditions are met. The mandatory nature of CSR spending alone does not disqualify qualifying payments, leaving revision unavailable on these facts.

Reassessment notices concerning escaped income below the prescribed threshold cannot be issued after three years from the end of the relevant assessment year. A notice issued beyond that limitation is time-barred and void, rendering the consequential reassessment legally unsustainable. A pure legal challenge to such a notice may be admitted as an additional ground where it goes to the root of the assessment and requires no further evidence or factual verification.

Mandatory approval from the competent authority under Section 151 is required for a reassessment notice issued under Section 148 after three years from the end of the relevant assessment year. Approval contrary to that requirement renders the notice invalid. The jurisdictional objection, involving a pure legal question requiring no further evidence, was admitted at the threshold. Invalidity of the Section 148 notice resulted in quashing of the reopening proceedings and the reassessment order founded on it.

Reassessment initiated more than three years after the end of the relevant assessment year requires prior approval under Section 151(ii) from the Principal Chief Commissioner, Principal Director General, Chief Commissioner or Director General before an order under Section 148A(d) and notice under Section 148 may be issued. Approval by a Principal Commissioner is not competent for this purpose. The TOLA extension applied only to approval under Section 151(i) until 30 June 2021 and did not validate later approval by an incorrect authority. The Section 148 notice, reassessment proceedings and consequential assessment order were therefore without jurisdiction and quashed.

Section 54F exemption requires the assessee to reinvest capital gains in a residential property acquired in the assessee's own name. Applying the jurisdictional High Court's interpretation of the corresponding exemption under Section 54B, investment in a property standing solely in the spouse's name does not meet that statutory condition. Accordingly, capital gains reinvested in the assessee's wife's residential property do not qualify for deduction under Section 54F, and the claimed exemption was disallowed.

Capital-gains taxability on transfer of alleged rural agricultural land depends on factual verification that the land was a capital asset under the Income-tax Act. The inquiry must establish the land's precise location, its distance from relevant municipal or cantonment limits on the transfer date, applicable notifications, and the land's nature and use. Where lower authorities have not examined these statutory conditions despite competing material on urban inclusion and agricultural character, the capital-gains addition requires fresh examination after providing the taxpayer an adequate opportunity to substantiate the land's status.

Section 43CA does not apply to flat sales concluded through booking, allotment and agreement before the provision's commencement merely because registration occurs later; the resulting stamp-duty valuation difference is not brought within that provision. Interest on capital borrowed for a real-estate business may be deducted as a period cost, including where the project is stock-in-trade, subject to verifying the business nexus and preventing double deduction through work-in-progress. Foreign exchange loss on consultancy liabilities and monetary-item settlement is revenue expenditure under Accounting Standard 11 where it lacks a direct connection with bringing inventory to its present location or condition, and is not capitalised to project cost.

Penalty for additions relating to interest received on enhanced compensation cannot be sustained where the taxability of that interest is a debatable legal issue and judicial views diverge. The absence of a settled legal position prevents penalty from being imposed merely because the addition was made. Penalty connected with such interest income was therefore deleted in favour of the assessee.

Reassessment limitation for assessment years up to 2021-22 remains governed by the earlier regime through the first proviso to section 149(1)(b). For AY 2017-18, the six-year limitation expired on 31 March 2024. A section 148 notice issued on 31 August 2024 was therefore time-barred and was set aside in favour of the assessee.

Penalty proceedings cannot rest on a cyclostyled show cause notice that leaves irrelevant particulars unstruck and fails to specify the applicable charge. Such vagueness prevents an effective response and makes the notice incapable of forming a valid foundation for penalty. Applying the Full Bench ruling relied on by the Tribunal, the penalty was treated as invalid because the notice did not clearly communicate the charge to be answered.

Prior notice to an applicant is required before rejecting an application for approval under Section 80G(5B). Where the absence of notice is undisputed, the rejection is procedurally infirm and cannot be sustained. Consequently, the Revenue's proposed challenge to the approval was not entertained, and questions concerning the applicant's substantive eligibility for approval did not arise for consideration.

Compounding of income-tax offences addresses the effect of a reduced penalty on eligibility for relief from prosecution, including the principle that penalty reduction may bar prosecution. It also concerns the binding force of an unchallenged writ direction and the limits of contempt jurisdiction to modify an earlier order. Compounding fees must be calculated and communicated within 60 days, with one month allowed for payment after the amount is communicated. Questions of law remain open.

Section 107(11) of the CGST/HGST Acts requires the Appellate Authority, after necessary inquiry, to confirm, modify or annul the decision appealed against. Its structure is analogous to Section 35C of the Central Excise Act, under which an appellate forum cannot dismiss an appeal merely for default or want of prosecution. A party's non-appearance may justify ex parte consideration, but does not authorise dismissal without adjudication on the merits. Appeals under Section 107 must therefore be decided on merits rather than dismissed for non-prosecution.

Schedule I now permits e-commerce entities to operate an inventory-based e-commerce model exclusively for exporting goods or products manufactured or produced in India. Such exports must comply with the Foreign Trade Policy 2023, the Handbook of Procedures, and the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015. For exports permitted under this new entry, the existing restrictions on business-to-consumer transactions and inventory-based e-commerce under entries 15.2.1 to 15.2.4 do not apply. The amendment takes effect from its publication in the Official Gazette.

Eligible holders of Advance Authorisations under SION E-52 may submit applications for a one-time conversion to Tariff Rate Quota (TRQ) for raw sugar imports from 3 September 2026 through 7 September 2026, inclusive. The extended application window aligns with the extended TRQ Scheme application period, and 7 September 2026 is the final submission date. All conditions prescribed for the conversion under the earlier public notice and corrigendum remain applicable. DGFT may amend, modify, relax or withdraw provisions, subject to the Foreign Trade Policy and applicable law.

The National Assessment Centre Portal provides a common digital repository for trade stakeholders and Customs formations to access NAC decisions, legal precedents, CAAR rulings, audit objections, advisories, alerts, meeting records and assessment-related material. Keyword-based search and document download functions support access to information on classification, valuation, policy-intervention issues and trade facilitation. Each NAC must use role-based credentials to upload, update and manage records within its allocated commodity and functional domain, with priority for issues raised in CCFC/PTFC discussions. Regular use and updating are intended to promote consistent assessments, reduce divergent practices, improve compliance and strengthen transparency and certainty in Customs administration.