CENVAT credit is admissible on duty-paid MS plates, angles, channels, beams and similar iron and steel items used to install, repair or maintain plant and machinery in a factory. The view that Chapter 72 structural steel items cannot qualify as inputs for fabrication, repair or maintenance of capital goods is unsustainable following the overruling of the Larger Bench view in Vandana Global. Iron and steel items used in relation to manufacture remain eligible even where the resulting structure is embedded to earth; such embedding does not, by itself, negate credit eligibility.

Cenvat credit is admissible on steel items used before 07.07.2009 to fabricate conveyor gantries, crane platforms, bag-filter and air-slide parts, cable trays, fan ducts and silos within a factory. Applying the user test, steel items used as components, accessories or supporting structures integral to plant and machinery qualify as capital goods or inputs under the Cenvat Credit Rules, 2004, rather than as materials for constructing factory buildings or sheds. The 2009 amendment excluding specified structural items is not clarificatory and does not apply retrospectively to the relevant period.

Recovery of annual differential refund self-credit was barred by limitation because the self-credit had been disclosed in monthly refund claims and ER-1 returns. The Department knew of the availment, verified it, and issued verification certificates; therefore, it could not invoke the extended limitation period for the show-cause notice covering the relevant financial years. The demand was consequently time-barred and unsustainable.

Regular bail in money-laundering proceedings requires satisfaction of the statutory twin conditions. A surviving predicate crime treated as a scheduled offence can sustain money-laundering proceedings despite quashing of another FIR and the applicant's omission from the predicate-offence charge-sheet. Money laundering may be prosecuted independently where material indicates involvement in processes connected with proceeds of crime. Statements recorded under the statutory investigation power, witness evidence, alleged forged reports, export clearances, invoices, adulteration allegations and company receipts were identified as prima facie material of knowledge and involvement. Detention following filing of the complaint and medical material did not establish grounds for release; regular bail was refused.

A show cause notice initiating customs broker licence revocation, security deposit forfeiture and penalty proceedings must precisely state the acts or omissions constituting each alleged regulatory contravention. Reproducing an earlier order or investigation material without identifying the specific allegations leaves the noticee to decipher the charges and fails to provide an adequate foundation for adjudication. Where the notice remained vague and omitted allegations concerning the asserted violations, the resulting revocation, forfeiture and penalty order could not be sustained.

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.