Clubbing and transfer of FIRs arising from the same allegations and forming one transaction require a consistent investigative forum, as parallel investigation is improper. The operative direction was corrected to align with that reasoning: the later FIR registered at Gurugram must be clubbed with and transferred to the earlier FIR registered with the Economic Offences Wing, Delhi. The clarification only rectified the transfer inconsistency and did not permit selection of an investigating agency.

Article 21 protection of life and personal liberty extends to timely pronouncement of reserved High Court judgments, particularly where custody or urgent remedies are involved. A nationwide framework under Article 142 requires High Courts to endeavour to deliver reasoned reserved judgments within three months, supported by priority treatment, administrative monitoring, reassignment after continued default, and remedies for early pronouncement or transfer for fresh hearing. Reasoned judgments should ordinarily be uploaded within 24 hours of open-court pronouncement; urgent operative orders require reasons within seven days, extendable to fifteen days for practical difficulty. Status updates, advocate communication, escalation, and corrective measures promote transparency.

Restoration of an appeal dismissed for failure to remove defects, including mandatory statutory pre-deposit, requires sufficient cause supported by a bona fide, diligent and documented explanation proportionate to the delay. Service of Registry communications and repeated non-appearance weigh against restoration where the appellant fails to establish compliance efforts or justified inability to act. An unexplained delay of nearly five years, coupled with unsupported grounds for non-compliance with pre-deposit, does not satisfy the sufficient-cause standard. Rejection of restoration raises no substantial question of law or perversity on these facts.

Section 85(3A) of the Finance Act, 1994 requires a service-tax appeal to be filed within two months and permits condonation for sufficient cause only up to one additional month. Delay beyond that statutory maximum cannot be condoned because the Commissioner (Appeals) and the Tribunal lack jurisdiction to extend the prescribed limitation period. A service-tax appeal filed 101 days after expiry of the normal filing period therefore remains barred by limitation, and the Commissioner (Appeals)' limitation finding operates against the assessee.

Residual penalty under the Customs Act requires identification of a specific statutory provision contravened where no express penalty is otherwise prescribed. A classification dispute alone does not establish a contravention by a customs broker for this purpose. Because the adjudicating authority did not identify any provision breached by the broker, and that omission was accepted, the residual penalty was unsustainable and was set aside.

National Litigation Policy monetary limits restrict Revenue appeals in customs matters where the revenue involved is below the prescribed threshold. The Tribunal dismissed the Revenue's appeal on that basis. No substantial question of law arose from that dismissal, so the connected customs appeal was also dismissed. The stated effect is to prevent continued litigation below the threshold where no legal issue warrants review.

Cash deposits during demonetisation may be satisfactorily explained by documented prior bank withdrawals and loans where the Revenue does not dispute the withdrawals or establish that the cash was used elsewhere. Mere passage of time between withdrawal and redeposit, or the obtaining of a later loan, does not by itself show that the withdrawn cash was unavailable. Treating deposits as unexplained money requires material disproving the stated source rather than presumptions about the cash's utilisation. On the stated facts, the explanation supported by prior withdrawals was sufficient, making an addition for unexplained money unsustainable.

Loss arising from transfer of non-performing assets to an asset reconstruction company crystallises when the loan portfolio is transferred for cash and security receipts and the loan accounts are closed. RBI norms require derecognition of transferred financial assets and write-off of any shortfall against net book value. Where previously deducted bad-debt provisions have already been reversed in tax computation, allowing the transfer loss does not create a double deduction. The loss is characterised as a revenue trading loss incidental to banking business, rather than a contingent or notional loss, and is allowable as a business loss under Section 28 of the Income-tax Act, 1961.

Exempt agricultural income requires authentic corroborative material showing that agricultural operations were actually carried out within the scope of the Income-tax Act. Mere ownership of agricultural land does not establish that agricultural income was generated. Where no supporting evidence is produced, the claimed agricultural income may be treated as income from other sources. A materially identical claim rejected for an earlier assessment year may not warrant a different treatment when the facts remain unchanged and no justification for departure exists.

Interest on fixed deposits maintained to secure release of retention or security money forms part of eligible-business profits for deduction under section 80IA(4). An additional deduction resulting from depreciation reallocation requires verification of the computation's factual and legal correctness before consequential relief is allowed. Section 14A read with Rule 8D does not permit expenditure disallowance where no exempt income arises in the relevant year; the Finance Act 2022 Explanation operates prospectively from 1 April 2022. Purchases supported by invoices, banking records, supplier tax returns, delivery and inventory documents cannot be characterised as bogus without evidence that payment returned in cash.

Penalty for concealment or furnishing inaccurate particulars under Section 271(1)(c) does not arise solely because a deduction for provision for bad and doubtful debts is disallowed. Liability requires a finding that income was concealed or that particulars furnished were false or erroneous. Where the claim concerns eligibility of rural branches and is made bona fide, disallowance alone does not establish either statutory condition. The penalty is therefore not leviable merely on account of the rejected deduction claim.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the interests of revenue. Where a limited-scrutiny assessment had called for and examined evidence on cash deposits, an allegation of inadequate enquiry or brief reasoning could not justify revision without identifying a specific error in the assessment findings or evidence. Directions to examine agricultural income exceeded the limited-scrutiny issue. The revision and consequential assessment were therefore unsustainable and quashed.

Audited books and remand material identifying balances as trade creditors, without identified defects, did not support treating the entire amount as unsecured loans; only a limited estimated addition was retained. Personal use of a motor car justified a proportionate, rather than total, depreciation disallowance. An electricity bill in the landlord's name did not justify a full ad hoc disallowance of trading-business administrative expenses. Supporting material for groundnut kharajat expenses made the earlier full disallowance excessive, although a limited estimate was retained.

Revision under Section 263 remains available for an assessment approved under Section 153D; such approval does not exclude revisionary jurisdiction. Absence of a Document Identification Number on the approval did not invalidate revision proceedings in light of the Supreme Court's interim stay in the relied-upon authority. Lack of inquiry into substantial bank cash deposits rendered the original assessment erroneous and prejudicial to Revenue, permitting revision. However, once unrebutted audited accounts, GST returns, cash records, sales documents, bank records, debtor ledgers and cash-flow details explained the deposits, a fresh assessment could not be directed without identifying deficiencies or adverse material.

Condonation of delay requires a cogent, satisfactory explanation showing sufficient cause and diligent conduct. Failure to regularly check emails carrying assessment intimations was unsupported and inconsistent with regular online return filing in subsequent years. Neither the assessee nor its consultant verified the assessment status for over eight years, constituting gross negligence rather than circumstances beyond its control. The 3018-day delay in filing the appeal before the Commissioner (Appeals) was therefore not condoned, and refusal of condonation was sustained.

Eligibility for staff and labour bonus deductions under Section 43B depends on verifying whether payment occurred within the statutory time permitted, including payment before the return-filing due date where applicable. Provident fund liabilities require separate verification of the actual deposit dates in the Government account before applying the governing legal rule. Both deductions therefore turn on factual confirmation of payment or deposit dates against the relevant statutory deadlines; neither claim can be conclusively determined without that verification.

Exemption under Section 10(26) is not automatic on the basis of Scheduled Tribe status alone. The claimant must furnish material establishing fulfilment of the statutory conditions and satisfactorily explain cash deposits. Non-participation in assessment proceedings and failure to provide reconciliation or source evidence prevent acceptance of the exemption claim on the available record. Where Scheduled Tribe status is undisputed and eligibility remains possible, the claim and the source of cash deposits require fresh determination after an adequate opportunity to submit supporting evidence.

Effective service of hearing notices is integral to reasonable opportunity and natural justice in appellate proceedings. Ex parte quantum orders passed after remand were unsustainable where later notices were sent to email addresses not belonging to the assessee or stated in its appeal memoranda, particularly when adjournments during the Covid-19 period had been acknowledged and substantial material required verification. The quantum assessments were remanded for fresh merits adjudication after a proper hearing. Connected penalty proceedings, arising from the same search-related documents and affected by the same deficient notice service, were also remanded on identical terms. The assessee must participate diligently without unnecessary adjournments.

Exemption under section 10(46) requires the claiming body or authority to be notified by the Central Government in the Official Gazette under section 10(46)(c). A pending application for notification does not satisfy this mandatory condition for the relevant assessment year. Pending writ proceedings concerning the requested relief likewise do not replace or suspend the notification requirement. Consequently, exemption under section 10(46) is unavailable until the requisite Central Government notification has been issued.

Functional comparability under the Transactional Net Margin Method requires similarity in functions, products and economic circumstances; a government-supported copper producer is unsuitable for comparison with a steel-wire and rod manufacturer. Profit level indicator margins should be recomputed from annual-report figures. Interest on a subordinated loan to a Thai associated enterprise is prescribed at 9%, while corporate guarantee commission is benchmarked at 0.5%. For captive power, market value for the Section 80-IA deduction is the electricity board's tariff charged to industrial consumers, not its purchase price. Further disallowances of miscellaneous and foreign travel expenses are impermissible where prior disallowances already exceed the proposed adjustments, as they create double disallowance.