Contractual under-loading charges arising from idle freight under a fuel supply agreement are deductible business expenditure where the agreement places liability on the seller and recovery occurs through sale-bill adjustments. As commercial obligations incurred in ordinary coal-supply operations, they are not expenditure for an offence or conduct prohibited by law under Explanation 1 to section 37(1). Demurrage for delayed loading or unloading at railway sidings is compensatory for extended use, storage and custody facilities and incidental to goods transportation. It likewise remains deductible where it is not a fine or statutory penalty. This treatment sustains deletion of disallowances for both categories of expenditure.

Remuneration received by a working partner is generally taxable as business income. However, the proviso to Section 28(v) excludes salary or remuneration, including any part of it, that has not been allowed as a deduction to the firm under Section 40(b). Accordingly, remuneration disallowed to the firm is not chargeable in the partner's hands. This exclusion applies to both salary and remuneration and prevents taxation of amounts for which the firm received no corresponding deduction.

Section 68 addition for an unsecured loan or advance is unsustainable where the taxpayer establishes the creditor's identity, creditworthiness and transaction genuineness through PAN, tax return, financial statements, bank records, ledger entries and company master data. Sufficient reserves and surplus support the creditor's capacity, while receipt and repayment through banking channels with matching accounting entries support genuineness. A prior statement by an alleged entry operator does not, without evidence of control over the creditor during the relevant year or linkage to the transaction, establish that the loan was an accommodation entry. The taxpayer consequently discharges the burden of proof under Section 68.

Interest expenditure cannot be allocated to or capitalised in capital work-in-progress when available interest-free funds exceed the value of that work-in-progress and are sufficient to finance it entirely. In the absence of a demonstrated nexus between borrowed funds and the capital asset, related interest disallowance is unsustainable. The interest expenditure therefore remains outside the cost of capital work-in-progress.

Cash deposits sourced from a nephew's agricultural-land sale proceeds and existing cash in hand are not unexplained where sale deeds substantiate the sale and receipt of consideration. The family relationship, sale transaction and receipt of cash support the stated source when they remain undisputed. A minor difference between sale consideration and the deposited amount, or the seller's ability to maintain a separate bank account, does not by itself displace that explanation. The deposits are therefore satisfactorily explained, and no addition for unexplained money under Sections 68 or 69A is warranted.

Unsigned Form No. 36 appeal memoranda remained defective despite Registry notices requiring rectification within ten days. As the defects were not removed by the hearing date, the appeals were dismissed as defective. The outcome turned on non-compliance with the procedural requirement to file signed appeal memoranda and cure notified defects.

Arm's-length pricing of intra-group management support services requires application of the benefit test: services must be rendered and provide economic or commercial value, while shareholder and duplicative activities are not chargeable. Service agreements, cost-allocation workings, benchmarking support and functional material can establish rendition and benefit; acceptance of part of the payment further supports that conclusion. Inclusion in a TNMM cost base does not alone prove benefit but may corroborate operational use. A 5% mark-up on indirect costs within the comparable range was consistent with low value-adding intra-group service principles. Pricing the disputed services at nil was unsustainable, requiring deletion of the transfer-pricing adjustment.

Pending proceedings before a larger Supreme Court Bench do not require deferral where the applicable authority remains unstayed and any interim restraint does not cover it. For assessments under the DRP mechanism, sections 144C and 153 operate together: DRP directions remain part of the assessment process, while section 144C(13)'s prompt-finalisation requirement does not displace section 153's outer limitation. Final assessment orders issued after the applicable statutory deadline are barred by limitation and jurisdictionally invalid, notwithstanding compliance with DRP directions.

Income-tax assessment jurisdiction at Indore rested on the assessee's electronic returns identifying Ward 3(1), Indore as the Assessing Officer, acceptance of assessment there for an earlier year, and service of notices at the communication address provided in the returns. Scrutiny selection through the computer-assisted system did not undermine that jurisdiction. No statutory objection to jurisdiction was raised, and the proposed transfer lacked confirmation that an operating office existed at the stated Maharashtra address. As adequate notice and opportunity were provided, the assessee's non-participation did not establish a breach of natural justice. The assessment and refusal to transfer were therefore not invalid for want of jurisdiction.

Recovery of a disallowance arising from alleged non-deduction of tax at source should remain deferred where the related demand for the same assessment year has already been stayed pending statutory appeals after the stipulated deposit. Because the disallowance under Section 40(a)(ia) arose from the same underlying issue, recovery should not proceed until the appeals are decided. The merits of the tax liability and the depositors' claimed exemption remain unadjudicated. The statutory appeals should be disposed of expeditiously, preferably within three months.

Penalty proceedings for failure to deduct tax at source remained in abeyance until disposal of the taxpayer's appeal against the tax-deduction-default order. Related expenditure disallowances for tax-deduction non-compliance resulted in assessment orders for several assessment years, which were separately stayed. As penalty action was deferred pending appellate disposal and no further directions were required, the related writ petitions and miscellaneous petitions were closed without costs.

Tax recovery arising from tax-deduction assessments was directed to remain in abeyance pending the Tribunal's final decision, subject to protection of the Revenue's interests. The taxpayer had already deposited part of the disputed demand and undertook to make a further deposit. Recovery was stayed on condition that Rs. 30 crores be deposited within four weeks, preserving security for the disputed tax liability during the proposed appellate proceedings.

The PMLA's statutory twin conditions apply equally to anticipatory bail in money-laundering matters. Bail-stage assessment is based on available material and probabilities, without a mini-trial; Section 50 statements may be considered with corroborative bank-account analysis and a financial trail. Repeated non-compliance with summons may be relevant to assessing whether an applicant is avoiding the inquiry. Where the material does not provide reasonable grounds to believe that the applicant is not guilty, anticipatory bail is unavailable. Money-laundering proceedings are distinct from predicate-offence proceedings, so pre-arrest protection in the predicate offence does not automatically extend to a PMLA proceeding.

Anticipatory bail for money laundering under the Prevention of Money Laundering Act, 2002 is subject to the twin conditions requiring reasonable grounds to believe that the applicant is not guilty and will not commit an offence while on bail. Bail protection in a predicate offence does not automatically apply to the separate offence of money laundering. Statements recorded under the Act, when corroborated by bank-account analysis and a financial trail, may link a person to alleged proceeds of crime. Non-compliance with personal-appearance summons, a prima facie fund trail, and the gravity of economic offences may preclude satisfaction of the statutory conditions and result in denial of anticipatory bail.

Delhi GST amendments introduce a three-year limitation for furnishing outward-supply details, returns, annual returns and e-commerce operator statements, subject to notified permission for delayed filing. Input tax credit is barred for goods or services used for corporate social responsibility obligations, while registration exemptions may be notified for specified categories. Best-judgment assessment return-filing periods are extended, with a further period available on payment of additional late fee. Appeals lie to the Goods and Services Tax Tribunal constituted under the central GST law.

Section 128 powers amend the sixth proviso by replacing 30 June 2023 with 31 August 2023 as the operative deadline. The substituted date is deemed to apply from 30 June 2023, giving the amendment retrospective commencement from that date.

AEO certificates remain valid for three years for AEO-T1 and AEO-T2 entities and five years for AEO-T3 and AEO-LO entities. Certificates that expired or were due to expire between 1 April 2021 and 31 May 2021 were extended until 30 June 2021 to facilitate renewal affected by COVID-related restrictions. The extension is unavailable to entities found ineligible for continuation under the AEO Programme.

Reporting requirements for Rupee accounts maintained by non-resident banks through authorised dealer banks are dispensed with immediate effect. Authorised dealer Category-I banks are no longer required to furnish annual updated lists of offices or branches maintaining such accounts. The obligation to report temporary overdrawals by overseas branches or correspondents exceeding the permissible limit and remaining unadjusted beyond the prescribed period is also discontinued.

Export reporting requires a departing conveyance to declare its identification, operator, departure details, cargo, stores, and private property held by the person in charge and crew. Cargo declarations cover transport references, packages, marks, quantity, goods description, exporter, destination, and shipment particulars. Stores must separately identify non-duty-paid consumable and non-consumable articles. The person in charge or agent must certify that no undeclared private property is on board and attest that the particulars and supporting documents are full and true before customs closure.

Registration for filing import manifests requires the applicant's name, Permanent Account Number and address, with particulars of each partner or director where the applicant is a firm or company. The application must identify authorised persons who will undertake manifest filing, specify their educational qualifications, and enclose a contract, memorandum of understanding or agreement with the foreign authorising agent. The applicant must declare the correctness of the particulars and sign the application.