CBIC's litigation policy provides that departmental customs appeals should not be filed before CESTAT where the duty involved is below the prescribed monetary threshold, and appeals already filed in such matters should be withdrawn. The policy operates as a monetary-limit filter for Revenue litigation and avoids consideration of the underlying dispute on merits where the threshold condition applies. The text concerns multiple customs appeals stated to fall below that limit.

Delayed electronic filing of Form 10B does not by itself disentitle a charitable trust to exemption under section 11 where the audit report was obtained and digitally signed before the prescribed return-filing date, uploaded before the extended due date and before return processing, and the delay arose from a bona fide belief that it had already been uploaded. The filing requirement is described as directory, allowing verification of the audit report and consideration of the substantive exemption claim. Exemption may be allowed if the claim is otherwise admissible, rather than being denied solely for the procedural lapse.

Reassessment initiated after four years is invalid where the underlying transactions were examined in the original assessments, the recorded reasons identify no fresh material, and they do not allege failure to make a full and true disclosure of material facts. Reconsidering previously examined material constitutes an impermissible change of opinion, rendering the reassessment proceedings and consequential orders void. Disallowance relating to exempt income cannot be made by applying rule 8D without the Assessing Officer recording satisfaction on the correctness of the taxpayer's claim. Business-expenditure disallowance is also unsustainable where supporting details and books were furnished, no defects were identified, and no evidentiary basis supported the adjustment.

Exemption for an eligible trust cannot be denied solely because Form 10B was electronically filed after the prescribed date where the audit report was available before return processing or assessment. The audit-report requirement is substantive, but the timing and mode of electronic filing are procedural. Form 10B filed before processing under section 143(1) must be verified, and the exemption claim should be allowed if the trust otherwise satisfies the applicable conditions.

Prior intimation of a proposed return-processing adjustment is mandatory before the adjustment is made. Where no evidence establishes that such intimation was issued, the adjustment is procedurally invalid, and a later scrutiny assessment does not cure that defect. The adjustment was therefore set aside, with the matter restored for fresh processing after notice of the proposed adjustment is issued.

De novo remand after admission of legal additional grounds and completion of remand proceedings was treated as unwarranted, requiring appellate adjudication. Business income estimated through a gross-profit rate could not also include a separate addition for commission already recorded in the profit and loss account, preventing duplication. Partners' explained capital contributions could not ordinarily be assessed as unexplained credits in the firm's hands; any enquiry lay in the partners' individual assessments. Unsecured loans supported by confirmations, tax identifiers, bank records and tax returns could not be treated as unexplained, except for two unsupported creditors. The gross-profit addition and the unexplained-credit addition relating to those creditors remained sustainable.

Payments by the Forest Department to Van Suraksha and Prabandh Samitis for conservation and reforestation were characterised as community-participation payments rather than contract payments. The Samitis operated as local groups under the State joint forest-management framework; the scheme excluded contractors and middlemen, and no contractual relationship with the Department existed. CBDT Circular No. 502 treated comparable community-participation payments as outside Section 194C. A coordinate-bench decision on identical facts was treated as binding on assessing and appellate authorities unless stayed or displaced by a superior-court ruling; a pending departmental appeal did not affect its operation. Consequently, no tax deduction at source liability or related default consequences arose.

The Finance Act 2022 Explanation to Section 14A is described as prospective from assessment year 2022-23; for earlier years, disallowance cannot exceed exempt income and must exclude investments yielding no exempt income. Employee stock option cost reimbursed to a holding company retains its revenue character where incurred to compensate, retain and secure employees' services, and is allowable as business expenditure. Tax deducted at source credit appearing in the latest Form 26AS after return filing should be granted. The unadjudicated debenture-issue expenditure ground requires a reasoned first-appellate determination.

Revision under section 263 was valid because the Assessing Officer made no specific inquiry or verification into a material deduction claimed as "any other amount as deduction" or the applicability of dividend-stripping provisions, despite complete scrutiny selection. Explanation 2(a) deems an assessment order erroneous and prejudicial to Revenue where required inquiries or verification were not undertaken. The distinction between complete absence of inquiry and inadequate inquiry was decisive: authorities involving some inquiry, or relating to periods before Explanation 2(a), did not apply. The assessment order was therefore erroneous and prejudicial to the interests of Revenue.

Cash deposits during demonetisation may be explained by accumulated savings from long-term unorganised housekeeping, cleaning, babysitting and caregiving work, together with cash received from a family member. Where the explanation is plausible and consistent with the taxpayer's work and circumstances, the absence of documentary evidence of earnings alone does not justify treating the deposits as unexplained money. The addition for unexplained cash deposits was deleted.

Reassessment under Section 147 cannot rest solely on tax-audit disclosures concerning Section 14A disallowance when the same issue was specifically examined and accepted in the original scrutiny assessment. The assessing officer had sought and accepted the taxpayer's explanation that no significant expenditure was incurred to earn exempt income and that investments came from personal funds. Reopening on the identical audit-report material, without subsequently received material, amounted to an impermissible review of an earlier assessment. Any inadequacy in the original enquiry could instead be addressed through revisionary jurisdiction. The reassessment notice, consequential reassessment order, and disallowance were treated as void.

Client code modification could not support reassessment where the recorded reasons omitted the allegedly modified client code and relevant scrip, and no cogent material linked the assessee to a non-genuine transaction. SEBI material showed that the named broker had ceased trading before the relevant year, undermining the alleged transaction. General investigation information, without a material nexus to income escaping assessment, created only suspicion rather than a sustainable basis for the addition. The alleged artificial-loss addition was deleted.

Reassessment notices issued after expiry of the extended three-year period required approval from the higher specified authority under Section 151(ii). The relaxation provision permitted approval under Section 151(i) only until 30 June 2021. Consequently, a notice issued on 29 July 2022 with sanction from the Principal Commissioner, rather than the authority prescribed by Section 151(ii), lacked a jurisdictional precondition. The reassessment notice and consequential proceedings were invalid for defective statutory approval.

Additional evidence relating to unsecured loans, share valuation and futures-and-options losses may be admitted under Rule 29 where it is material to disputed additions, was not withheld deliberately, and is necessary for a just decision. Where factual verification is required, the affected issues may be remanded for fresh consideration after allowing the other side an opportunity to respond. Bad debts arising from loans advanced in the ordinary course of a money-lending business may be deductible when written off in the accounts and the related interest has been offered to tax. Under the post-amendment position, proof of actual irrecoverability is not required if the statutory conditions are met.

Long-term capital-gain addition based on stamp-duty valuation of one co-owner's share was deleted because the same property sale had been accepted as genuine for the other co-owners holding equivalent shares. Verification of the sale agreement and registered sale deed in those assessments supported consistent treatment of materially identical interests in the same transaction. Applying a different standard to one co-owner would create unequal tax treatment; accordingly, no addition was sustained for that co-owner's share.

Reassessment based on investigation information identifying a supplier as an accommodation-entry provider may be supported by fresh tangible material indicating that income escaped assessment. Where purchases are treated as non-genuine, the addition may be confined to the profit element rather than the full purchase value. Consistency is central when the same supplier, factual matrix and circumstances remain unchanged across assessment years: an earlier profit-rate approach should ordinarily continue absent a material change in facts or law. A 12.5% estimate is presented as representing the benefit derived from grey-market purchases.

A penalty notice under section 271(1)(c) must clearly specify whether the charge is concealment of income or furnishing inaccurate particulars of income, as the two limbs have distinct meanings. A notice or penalty order that leaves the charge unspecified is vague, demonstrates non-application of mind, and cannot be cured by assessment proceedings or other material. Where neither document identifies the applicable limb, initiation of penalty proceedings is invalid and the penalty is unsustainable; the penalty merits need not be examined.

Reassessment initiated beyond three years from the end of the relevant assessment year requires approval under Section 151 from the Principal Chief Commissioner or Principal Director General, or, where absent, the Chief Commissioner or Director General. Approval by a Principal Commissioner does not meet this statutory requirement, invalidating the reassessment proceedings. Limitation must also be calculated by applying the rules for deemed notices and excluding the period allowed for response under Section 148A(b). Where the surviving period expires before issuance of the Section 148 notice, the notice is time-barred and consequential reassessment cannot stand.

Effective opportunity of hearing is required under the principles of natural justice and audi alteram partem before an assessment and consequential penalty action can be sustained. The text states that allowing only two days to respond, not considering an adjournment request, and the assessee's inability to upload its response denied an adequate opportunity to address the proposed assessment. It identifies the resulting assessment order, demand and penalty proceedings as untenable for breach of natural justice.

A faceless-assessment show-cause notice must allow at least seven days for a response under the applicable SOP. Allowing only six days deprives the assessee of the prescribed opportunity to respond and breaches principles of natural justice. Earlier lack of diligence by the assessee does not cure this procedural defect in the notice under challenge. The assessment and consequential orders were set aside, with the matter restored to provide a fresh opportunity to respond to the show-cause notice.