Corporate guarantees furnished to associated enterprises fall within capital financing under Explanation (c) to section 92B and require arm's-length pricing because they enhance the enterprise's creditworthiness while exposing the guarantor to risk. In the absence of an independently substantiated fee computation, a 0.5% annual guarantee-fee rate under Rule 10AB was treated as reasonable, sustaining the transfer-pricing adjustment. Guarantee-fee profit is not derived from the eligible activity of developing a Special Economic Zone and therefore does not qualify for deduction under section 80-IAB(10).

Estimated business-expenditure disallowances require a factual basis: where audited books are not rejected and no specific expense is identified as non-genuine, excessive, unverifiable, or unrelated to business, a blanket percentage-based disallowance is not justified. Cash deposits originating from recorded pre-demonetisation sales require assessment against cash books, sales and stock records, returns, reconciliations, and audited accounts; treating already recorded sales receipts as unexplained cash credits may result in double taxation. Unsecured loan credits require verification of creditor identity, creditworthiness, genuineness, immediate source of funds, and supporting tax and banking records; confirmations and subsequent repayments alone are not conclusive.

Section 270A distinguishes ordinary under-reporting, penalised at 50%, from under-reporting arising from misreporting, penalised at 200%. Enhanced penalty requires identification and proof of a specific circumstance exhaustively listed for misreporting. Omission of salary, interest or rental receipts from a return, even if detected in reassessment, may establish under-reporting but does not alone establish misrepresentation, suppression, unrecorded receipts, false entries or another prescribed form of misreporting. A generic allegation is insufficient, and an enhanced misreporting charge cannot be reconstructed on appeal or converted into ordinary under-reporting. Without an identified and established statutory circumstance, the enhanced penalty must be deleted.

Telecommunication and bandwidth service receipts are analysed as business profits rather than royalty or fees for technical services under domestic law and the India-UK tax treaty. Payments for bandwidth services do not constitute royalty where treaty royalty definitions, materially alike across the relevant treaties, do not cover those services. A domestic-law expansion of royalty, including Explanation 6 to section 9(1)(vi), cannot be imported into a treaty without bilateral amendment. Accordingly, the receipts remain business profits and are not taxable in India where no permanent establishment exists.

Delayed payment of tax deducted at source attracts compensatory interest under Section 201(1A) where the tax is not remitted within the prescribed period. Bona fide explanations, an accountant's medical exigencies, lack of awareness, payment within the same financial year, and availability of TDS credit do not alter that statutory consequence. Delayed furnishing of Form 26QB attracts the daily fee under Section 234E, subject to its statutory ceiling, irrespective of actual revenue loss. For the post-1 June 2015 period, Section 200A permits computation of that fee while processing the TDS statement. Bona fide conduct or hardship does not provide a statutory basis for waiver.

Bank fixed deposits made for at least six months from net consideration on transfer of trust property constitute acquisition of another capital asset for section 11(1A). Capital gains so reinvested qualify for exemption, and Form 10 is not required because the funds have been invested rather than accumulated for future application. Irrecoverable tax deducted at source, where it has not been claimed as a refund and directly relates to the trust's income receipts, qualifies as application of income. The trust may therefore claim exemption for qualifying capital-gains reinvestment and treat the TDS write-off as income application.

Capital-gains exemption for investment in a new residential house is governed by the provision applicable to the nature of the transferred asset, not merely by an incorrect statutory reference in the return. Where land was transferred and the record established the transaction, qualifying investment within the prescribed period, and disclosure of the claim, exemption under Section 54F could be considered despite an untenable claim under Section 54. The bar on an Assessing Officer accepting a fresh claim without a revised return does not limit appellate jurisdiction to admit a correctly described claim where all relevant facts are already on record. The capital-gains addition was therefore liable to be deleted.

Late fee for delayed filing of a TDS statement under section 234E may be computed only from 01.06.2015, when section 200A(1)(c) introduced the statutory mechanism for such computation. The mechanism operates prospectively and does not permit levy for any period before that date. Where a TDS statement is filed after 01.06.2015, the continuing filing default attracts late fee from 01.06.2015 until the actual filing date; any fee attributable to the preceding period must be deleted.

Fixed "refurbish and rebate" credits issued to distributors at a uniform percentage, without any obligation to repair defective products or linkage to actual repair costs, are trade rebates rather than consideration for contractual work or professional services. They therefore do not attract tax-deduction obligations or consequential disallowance for non-deduction. The deductibility of employees' contributions depends on verification through challans and supporting records that remittances were made by the prescribed statutory due dates; timely deposits must be allowed in accordance with law.

Reassessment notices issued on or after 1 April 2021 for Assessment Year 2015-16 fell outside the period available for completion under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Consequently, the notice and consequential proceedings under the substituted reassessment framework, including the preliminary procedure and reassessment, could not continue and were required to be dropped.

Reassessment for AY 2022-23 based on an alleged Section 43B deduction for tax deducted at source was invalid where original scrutiny had examined the relevant expenses, TDS and statutory liabilities. The challenged amount represented TDS on salary and other payments, not expenditure claimed as a Section 43B deduction; leave encashment was separately reported as a smaller deduction. Because the material had been furnished and considered in the assessment under Section 143(3), the reopening rested on a misreading of records, non-application of mind and a change of opinion, without fresh tangible material showing escaped income. The show-cause notice and consequential order were quashed.

Limitation under Section 153B requires court-ordered stay periods to be excluded during the initial computation under its Explanation, before the resulting composite deadline is tested for eligibility under TOLA. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge limitation and conflict with strict construction of tax limitation provisions. On this approach, the calculated deadlines for stayed years fell outside TOLA's extension window, while assessments for other years were made after the extended deadline. The search assessments, connected notices and penalty orders were therefore time-barred and liable to be quashed.

Reassessment under section 147 cannot serve as a review of claims already examined in the original scrutiny assessment. A valid reason to believe income escaped assessment requires a live nexus with tangible material; a changed inference from existing assessment records is insufficient. Where queries on depreciation, expenditure disallowance and pre-production income were raised and answered, and recorded reasons identify no fresh material or failure of full and true disclosure, reopening lacks jurisdiction. The resulting reassessment order is invalid as founded on a mere change of opinion.

Advance-ruling jurisdiction does not extend to entitlement to refund of accumulated input tax credit under the inverted-duty proviso, as refund determination is not among the specified advance-ruling questions. Classification and rate questions remain admissible where no pending or concluded proceeding exists; a verbal doubt during refund scrutiny is not a statutory proceeding. Rubberised Cork Sheets and Agglomerated Cork Sheets fall under Tariff Item 45041010 because heading 4504 covers agglomerated cork with or without a binding substance. They qualify for 5% GST from 22 September 2025; binder content or absence of natural-cork status does not negate the benefit.

Preparatory coaching, learning resources and academic support do not qualify for the educational institution exemption because the provider neither conducts prescribed examinations nor awards the recognised qualification or degree. Examination, registration and related fees remitted for students remain taxable unless all pure-agent conditions, including recipient authorisation and separate invoicing, are met. Printed materials, recorded lectures and digital resources supplied for a consolidated coaching fee are naturally bundled with coaching as the principal supply and are taxable accordingly. Foreign-exchange fluctuations retained on remittance of foreign professional fees are outside taxable value where they are not consideration for a distinct supply. Training and infrastructure support supplied to universities is taxable as education services.

Psyllium seeds supplied after storage in dry, ventilated conditions are treated as dried goods rather than fresh or chilled goods, because their condition at the time of supply governs GST treatment. They therefore do not qualify for the exemption applicable to fresh or chilled Psyllium seeds, or for the alternative exemption for goods of seed quality. The seeds are classified under tariff item 1211 90 13 as dried plants and parts of plants used in pharmacy and attract GST at 5%. The fresh-or-chilled versus dried distinction determines exemption eligibility.

Full payment of the prescribed fee is required to maintain an advance-ruling application under the CGST and KGST framework. The requirement arises under section 97(1), read with rule 104 of the corresponding rules. Where an applicant neither remits the balance fee nor responds to communications and hearing opportunities to rectify the deficiency, the application cannot be entertained and is not maintainable.

Full payment of the prescribed fee under the relevant central and State enactments is a mandatory precondition for entertaining an advance-ruling application. An application not accompanied by the full fee remains defective, and failure to cure that defect despite repeated opportunities prevents consideration of the questions raised on merits. Non-appearance or continued non-compliance by the applicant reinforces that the application cannot proceed.

Advance-ruling applications require full payment of the prescribed fee under section 97(1) of the CGST and KGST Acts read with rule 104. They must also identify the applicable statutory category of questions under section 97(2). Non-payment of the balance fee despite opportunities, failure to comply with hearing notices, and omission of the required question category constitute fundamental filing defects. These mandatory requirements determine maintainability, and non-compliance renders an advance-ruling application not maintainable.

Leasing a projector, server, UPS and VSAT for a single rental is treated as a mixed supply where the equipment is not naturally bundled in the ordinary course of business. Independent usability of each item, absence of customary industry bundling, lack of consumer expectation, and no ancillary or integral relationship prevent composite-supply treatment. A mixed supply is taxable at the rate applicable to its highest-rated constituent supply. As the projector attracts the highest rate, the lease is subject to 28% GST until 21 September 2025 and 18% GST thereafter.