Section 45(2) of the Income-tax Act, 1961 defers taxation of capital gains arising from conversion of land into stock-in-trade until the previous year in which the stock is sold or otherwise transferred. Where the converted stock is sold in stages under a development agreement, the corresponding long-term capital gains are chargeable proportionately in the relevant years. Assessing the entire gain in the year of conversion and execution of the agreement would result in double addition where corresponding gains are offered in the relevant years.

Diwali celebration expenses incurred at business premises with staff can qualify as business expenditure under Section 37(1) of the Income-tax Act, 1961, where they serve business purposes, including goodwill among employees and customers. General, office and sales-promotion expenses may be disallowed to the extent admitted or shown to be personal. Unverifiable bills alone do not justify a blanket disallowance of the remaining expenditure without a specific finding that it is personal or non-business expenditure.

Penalty under section 271B requires failure to obtain an audit or furnish the audit report as required under section 44AB; objections to the report's particulars alone do not establish that failure. Ledger entries, sale bills and bank statements can support an explanation that a business advance was settled through supply of goods and repayment of the balance, relevant to its treatment as unexplained money. Where business profit is estimated after rejection of books, evidence of electronic filing and subsequent furnishing of the audit report may require verification with an opportunity of hearing.

Environmental preservation expenditure is allowable in computing business income at the normal rate despite denial of charitable trust registration, where the assessee is treated as carrying on business. Section 37 of the Income-tax Act, 1961 governs qualifying expenditure incurred wholly and exclusively for business, while section 57 concerns expenditure for earning income from other sources. The claimed expenditure was supported by evidence, the books were not rejected, and the ad hoc disallowance lacked cogent reasons.

Late-filing fees under Section 234E cannot be computed during processing of TDS statements for assessment years 2012-13 to 2014-15 merely because processing occurred after 1 June 2015. Section 200A(1)(c) supplied the mechanism for computing those fees from that date. For a statement relating to assessment year 2013-14, processing after the amendment does not authorise the fee or consequential interest; the levy is unlawful.

Section 44AE of the Income-tax Act, 1961 defines a heavy goods vehicle by reference to a gross vehicle weight exceeding 12,000 kilograms and prescribes a weight-based presumptive income rate. Under the applicable framework, including the Motor Vehicles Act, 1988 and the CBDT circular, unladen weight is relevant to tractors or road-rollers. The heavy-goods-vehicle rate applies to goods carriages with a gross vehicle weight of 49,000 kilograms each that were not shown to be tractors or road-rollers, despite their lower unladen weight.

Tax deducted at source is available as a credit to the extent it relates to the corresponding income. The return was processed under Section 143(1) without granting the disputed credit, although Form 26AS reflected both the income and tax deducted. Credit had also been granted to a co-owner. The assessee is entitled to the credit relating to the corresponding income.

Revision of an assessment under section 263 requires an error prejudicial to revenue, including a failure to make necessary enquiries. Cash deposits supported by records, and explanations of liquidity, investments, property payments and profit ratios, do not justify revision where alleged discrepancies or adverse findings are unsubstantiated. Section 145A requires specified taxes, duties, cess and fees to be included in the valuation of purchases, sales and inventory. Separately recording GST and cess rather than including them in those valuations breaches that requirement and justifies revision. Fresh assessment remains confined to the valuation issue.

Penalties for concealment or furnishing inaccurate particulars on estimated additions for alleged bogus purchases are unsustainable where coordinate-bench decisions on identical additions support deletion and no distinguishing features or subsequent contrary rulings exist. Judicial discipline and consistency require those decisions to be followed. Penalties imposed under section 271(1)(c) of the Income-tax Act, 1961 on such estimated additions must therefore be deleted.

Writ jurisdiction may be exercised despite an alternative appeal to the Tribunal where an appellate order under section 250 of the Income-tax Act, 1961 involves an apparent procedural error and denial of an opportunity to be heard. Deciding an appeal ex parte before the deadline for written submissions violates natural justice and may justify setting aside the order and providing a fresh hearing and decision. The assessment merits remain open for that decision.

Transfer-pricing comparables for software and IT-enabled services must be functionally comparable, taking account of business models, outsourcing and differences between higher-end and routine services. Companies with abnormal profits attributable to extraordinary circumstances, including a merger and consolidated results, must be excluded where their inclusion would distort the mean profit level indicator. These exclusions prevent functionally dissimilar companies or distorted results from forming the basis of the arm's length price benchmark.

Reassessment beyond three years and aggregation of bogus-purchase expenditure across previous years are the tax issues.

Reassessment for assessment year 2014-15 raises the issue of whether a notice under Section 148 may be issued after expiry of the six-year limitation period under the old reassessment regime.

Examination-related printing and supply of materials constitute a composite supply of services where educational institutions own and provide the content, printing is the predominant element, and paper is ancillary. Classification follows the principal supply under heading 9989. Services supplied to qualifying educational institutions in relation to examinations are exempt from GST, including question-paper and admit-card printing, post-examination scanning and result processing, and printing of marksheets and certificates connected with completing examinations and obtaining recognised qualifications.

GST exemptions for government-related project services require supply to specified government or local authorities and a connection to entrusted functions; the training exemption requires supply to a specified government administration. A government-controlled society is not the Government merely because a programme is government funded. Incubation and capacity building in the project constitute a composite supply with incubation as the principal supply; project consultancy and related services attract GST at 18% without the claimed exemptions. Challenge fund grants, soft loans and other enterprise-support funds form part of taxable value on the available contractual evidence. Pure-agent disbursements may be excluded when Rule 33 requirements, including authorisation, recovery at actual cost and separate invoicing, are met. Services supplied by a recognised Technology Business Incubator qualify for a nil rate from the effective date of recognition, subject to the entry's conditions; earlier supplies remain unaffected.

Kraft paper bags with a base width below 40 cm are not exempt from GST and are classified under HSN 48194000. The specific reduced-rate entry for paper sacks and bags applies over the broader entry for goods under heading 4819, attracting GST at 5%. Input tax credit is available on inputs and input services used to manufacture the bags, since their supply is taxable, subject to the conditions prescribed under the applicable GST laws.

For the relevant period, input tax credit requires an invoice, receipt of services, actual payment of tax to the government and filing of a return; the later invoice-reflection requirement does not apply. The claimant bears the burden of proving eligibility. A certificate under the administrative circular is a verification measure, not an independent eligibility condition, and its discrepancy mechanism does not apply where the invoiced integrated tax is reflected in GSTR-2A. Eligible integrated-tax credit on an inter-State supply by a special economic zone unit is not wrongly availed merely because it is inadvertently recorded under central and state tax heads. Wrong-head payment provisions concern tax paid on a transaction, not credit claimed by the recipient.

Undisputed transitional credit remains available where a departmental portal failure prevents diligent, timely filing of a required return and the return is filed at the first available opportunity. Section 140 requires returns for the six months preceding the appointed date, while Rule 117 governs the transitional declaration. Substantial compliance and the principle that law does not compel the impossible inform this result. A fraud-based penalty cannot replace the non-fraud penalty proposed in the notice; section 75(7) bars confirmation of a demand on grounds not specified in the notice. Section 74 requires foundational facts supporting fraud, wilful misstatement or suppression with intent to evade tax; disclosed filing difficulty and perceived wilfulness alone are insufficient. Consequential relief extends to associated interest and penalty.

Non-consecutive tax invoice numbering is a technical irregularity where valid documents accompany interstate goods, the quantity and description match, and no unaccounted transaction or tax evasion is alleged. Rule 46 requires consecutive invoice numbers, but such a lapse alone does not justify detention or a penalty under section 129. Section 125 addresses general penalties for technical infractions, but its imposition requires deliberate noncompliance. A general penalty is not established without that requirement.

Findings of fictitious transactions require collective evaluation of the available evidence and an effective hearing where material facts remain unresolved after ex parte proceedings. Closure of premises following claimed discontinuance of business, subsequent cancellation of a supplier's registration, or absence of a particular document is not conclusive by itself. The taxpayer's burden of substantiating transactions must be examined, and the taxpayer must have an opportunity to respond and produce supporting records before an adverse finding.