Reassessment under Section 148 cannot rest on a different view of material already examined in the original scrutiny assessment. Where additions to fixed assets, borrowings, interest payments and capital work-in-progress had been scrutinised, including disallowance of interest and the proviso to Section 36(1)(iii), reopening based solely on the same balance-sheet material amounts to an impermissible change of opinion. In the absence of subsequent tangible information indicating escaped income, the reassessment initiation was invalid and quashed in favour of the assessee.

Revisionary jurisdiction under Section 263 requires both an erroneous assessment order and prejudice to Revenue interests. Where the assessment order expressly records that additional income disclosed during survey, including excess-stock income, was included in the return, a direction for further verification requires a demonstrated basis that the disclosure was omitted. In the absence of that basis, the twin statutory conditions are not met and revision cannot be sustained; the revision order was set aside in favour of the assessee.

Consideration from the sale of agricultural land disclosed as exempt income cannot be added merely because it was not credited to the business profit and loss account. Audited accounts and Form 3CD confined to the textile business did not require inclusion of milk-sale income offered under presumptive taxation or exempt agricultural income. Processing the return by treating the land-sale consideration as uncredited business income was therefore unsustainable, and the addition was required to be deleted.

Section 250(6) requires appellate orders to be written, identify the points for determination, record decisions on those points, and give reasons. Upholding an assessment solely because supporting material was not produced, without adjudicating substantive grounds on their merits, fails to meet these statutory requirements. Fair procedure requires a fresh opportunity where merits have not been considered. The appellate order was set aside, and all issues were remitted for fresh adjudication in accordance with law after allowing the assessee a reasonable opportunity of hearing.

Section 153D requires prior approval for each assessment year before passing a search assessment under Section 153A. A single consolidated approval covering multiple assessees and assessment years, without demonstrable independent examination of draft assessments, appraisal material and seized records, does not satisfy this statutory safeguard. Where the volume of records and limited time make meaningful scrutiny implausible, the approval is mechanical and invalid. The resulting search assessments for the relevant assessment years were annulled.

Where liquor-business receipts are accepted and profit is estimated from established business outflows, a separate addition for bank cash deposits attributable to the same business creates impermissible duplication and should be deleted. Profit estimation at 3% of evidenced business outflows was treated as justified where no return, books of account, or supporting evidence substantiated the claimed business loss. Payments for shop allotment and liquor purchases could therefore form the basis for determining business outflows and estimating taxable profit. Only the estimated business profit remains chargeable; a separate cash-deposit addition cannot coexist with that estimation.

Foreign tax credit under section 90/90A and an applicable tax treaty cannot be denied solely because Form No. 67 was furnished after the due date under section 139(1). Rule 128(9) prescribes the filing deadline for documentary proof of foreign taxes but does not provide that delayed filing forfeits the credit. The time requirement is therefore procedural and directory, while entitlement to credit remains substantive where the relevant foreign income has been taxed both in India and abroad. Delayed furnishing of Form No. 67 requires consequential recomputation of tax liability allowing the claimed credit.

Reassessment beyond four years is invalid where deduction-related scrap sales and job-work receipts were specifically examined in the original scrutiny assessment and no failure to disclose fully and truly all material facts is established. The proviso to Section 147 requires such disclosure failure for reopening after four years. Reliance solely on the existing assessment record, without tangible material indicating escaped income, amounts to an impermissible change of opinion. The reassessment was therefore quashed for lack of jurisdiction.

Delayed employees' provident fund contributions are not deductible when paid beyond the prescribed due date, while interest for delayed remittance of tax deducted at source is also not allowable as business expenditure. Forfeiture of a contract deposit after refusal to perform an awarded civil contract for commercial reasons is treated as deductible business expenditure where it is not incurred for an offence or an activity prohibited by law. An ad hoc disallowance of labour, machinery hire and repair expenses lacks support where books are not rejected, profits are not estimated, and no defects in vouchers or records are identified. The assessment is modified accordingly.

For unabated assessment years under search assessment proceedings, additions can be made only on the basis of incriminating material seized during the search and relatable to the relevant assessment year. Where no specific seized material is identified for the respective years, additions lack the required evidentiary basis and are unsustainable. This confines search assessments for completed, unabated years to matters supported by year-specific incriminating evidence.

Compulsory-acquisition compensation awarded or agreed under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 receives income-tax immunity under section 96, even without a separate exemption provision in the Income-tax Act, 1961. An exemption claim omitted from the original return may be considered where it is placed before the assessing authorities through a revised computation. The Dispute Resolution Panel's co-terminous powers include considering issues beyond objections and issuing binding directions. Taxable income is consequently recomputed after excluding qualifying compulsory-acquisition compensation.

Faceless reassessment initiated and completed before the e-Assessment of Income Escaping Assessment Scheme, 2022 came into force lacked statutory authority under Sections 151A and 144B. Where reassessment notices predated 29 March 2022, the faceless mechanism was unavailable because the scheme authorising that mode had not yet been notified. The resulting reassessment order was therefore without jurisdiction and void, requiring it to be quashed.

Penalty for concealment of income or furnishing inaccurate particulars requires a statutory notice that clearly identifies the specific charge. Because penalty proceedings are distinct from assessment proceedings, the taxpayer must receive unambiguous notice of the applicable limb of the penalty provision. Invoking both limbs without specifying which allegation is pursued renders the notice legally defective and prevents the penalty from being sustained.

Section 151A required notification of a scheme before faceless assessment, reassessment and related income-escaping assessment proceedings could be conducted. Although notices under section 142(1) were issued through the faceless regime from 13.12.2021, the faceless scheme was notified only on 29.03.2022. A reassessment order passed on 26.03.2022 under sections 147, 144 and 144B therefore lacked statutory jurisdiction, was non est, and the reassessment proceedings were quashed.

Expenditure on eviction, shifting and rehabilitation of encroachers is revenue expenditure where incurred to facilitate business operations rather than acquire a new capital asset, and is therefore allowable in principle. Deduction must nevertheless be quantified by actual payment evidence. Where vouchers do not support the entire recurring provision, public-sector status and compulsory audit requirements may justify limited additional relief on peculiar facts, without establishing a general precedent. Relief was granted only to a limited extent, while the remaining unsupported provision was disallowed.

Adjustments processed under section 143(1) become part of assessed income where the assessment order expressly adopts that processed income rather than returned income. The availability, or non-exercise, of a separate statutory appeal against an intimation does not allow the Commissioner (Appeals) to decline merits adjudication of an adjustment retained in the assessment order, particularly where issuance and service of the intimation are unproved. The appellate authority must adjudicate the adjustment on merits through a speaking decision after providing the assessee a reasonable opportunity of hearing.

Foreign Trade Policy amendments facilitate export invoicing and receipt of payments in Indian rupees. For exports to countries outside the Asian Clearing Union, export contracts and invoices may be denominated in Indian rupees or any foreign currency. The earlier general requirement that export earnings be received in a freely convertible currency is thereby eased, while applicable rules continue to vary according to destination.

Rule 86B non-compliance raises whether use of eligible ITC for the entire output tax liability creates unpaid tax for Section 50 interest. One view treats the breach as a mode-of-utilisation restriction rather than delayed tax payment, unless a statutory basis deems the cash portion unpaid. Sufficient Electronic Cash Ledger funds credited before the due date and continuously available may support a defence against compensatory interest, subject to ledger chronology and jurisdictional views. A contrary view distinguishes cash-ledger deposits from actual tax payment and treats the prescribed cash portion as payable.

Zero-rated supplies to SEZ units or developers for authorised operations may be made under LUT without IGST, with refund of eligible unutilised input tax credit, or on payment of IGST followed by supplier-side refund. The discussion presents differing views on whether IGST under the payment route is separately charged to the SEZ recipient or is borne temporarily by the supplier. It notes that supplier refund eligibility is subject to SEZ endorsement, authorised-operations requirements and a declaration that tax has not been collected from the SEZ recipient.

Foreign direct investment may use the automatic route where non-controlling beneficial ownership from a land-bordering country in the investor entity does not exceed 10%, subject to sectoral caps, entry routes and other applicable conditions. The beneficial ownership test applies at the investor-entity level. Eligible investors need not obtain separate prior Government approval after reporting relevant information to the Government. The framework replaces the earlier approval requirement applicable even to minimal beneficial ownership from land-bordering countries.