Import tariffs on Canadian products are set to be imposed by the United States at a 50% rate after bilateral negotiations did not produce an agreement. The measures cover products including hockey sticks and tongue depressors and affect a limited share of Canada's annual exports to the United States. Canada has indicated possible retaliatory levies, intensifying the bilateral trade dispute.

Judicial review of an ongoing tender is limited to the legality of the decision-making process, including arbitrariness, irrationality, bias, mala fides and procedural impropriety; it does not permit reassessment of comparative technical merit. Technical disqualification challenges may therefore be premature before financial bids are opened or successful bidders are identified, particularly where uninterrupted public services require timely procurement. Procurement rules and tender conditions requiring reasons for technical disqualification oblige disclosure of unsuccessful bidders' reasons and their own detailed scores. They do not require immediate disclosure during the process where timing is unspecified, procurement may be disrupted, and other bidders' comparative marks remain commercially confidential.

Supreme Court declined to interfere with the High Court's order but directed the respondents to provide the petitioner with a break-up of marks within ten days. The High Court's order does not prevent the petitioner from raising all contentions, including those previously raised. The special leave petitions and pending applications were disposed of accordingly.

Penalty under Rule 26(2) of the Central Excise Rules, 2002 for issuing excise invoices without delivery of goods requires the factual conditions of that provision to be established. Where no goods were available or involved, invoices allegedly enabled recipients to avail CENVAT credit but did not provide the factual foundation for penal action under the invoked rule. Applying an earlier decision concerning the same appellant, the penalty was not imposable.

Limitation for an intra-court appeal under the Companies Act requires filing within 30 days. A time-barred appeal should be accompanied by an affidavit-supported application explaining sufficient cause; failure to file it simultaneously is procedural and does not automatically require rejection. However, delay in filing both the appeal and the condonation application must be satisfactorily explained through evidence of due diligence. Seeking a certified copy only after limitation expired, coupled with an unexplained assertion that voluminous records required collation, does not establish sufficient cause. The delay-condonation application was therefore rejected.

Section 68 applies only to sums credited in the books during the relevant previous year when the taxpayer fails to explain their nature and source satisfactorily. An amount received through banking channels in an earlier financial year, recorded as an advance in audited accounts, and confirmed by the purchaser could not be treated as an unexplained cash credit in a later assessment year. Where the purchaser's identity and creditworthiness are undisputed, a Section 68 addition in the later year is unsustainable. The permissible assessment year is the year in which the credit is recorded.

CBDT instructions governing selection of potential reassessment cases required approval from the Chief Commissioner where information originated from an Income-tax authority. A subsequent clarification confirmed that the prescribed approval could not be substituted by approval from the Principal Commissioner. Approval recorded from the Principal Commissioner therefore failed to satisfy the mandatory administrative condition for issuing a notice under Section 148. The resulting notice, reassessment reopening, and reassessment were void.

Anonymous donations received by a trust pursuing both religious and charitable purposes fall outside section 115BBC(1), unless donors specifically direct them to an educational or medical institution run by the trust. Registration under section 80G does not establish exclusive charitable status because sections 80G and 115BBC operate independently. Expenditure on constructing a university building and acquiring books and periodicals for charitable and educational objects qualifies as application of income, as does an endowment contribution directly connected with educational activities. A genuine allowable charitable claim is not barred merely because it was not separately claimed in the return. Statutory interest requires consequential recomputation after assessment relief.

Approved corporate insolvency resolution plans govern pre-resolution statutory liabilities, including outstanding income-tax demands. Income-tax demands for the relevant assessment years therefore require reconsideration and consequential modification under the statutory mechanism to ensure consistency with the plan's binding effect. The Assessing Officer must take action to modify the demands in accordance with the approved resolution plan.

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.