Restoration of an appeal dismissed for failure to comply with mandatory pre-deposit requirements and repeated non-appearance requires a credible, substantiated sufficient cause. Receipt of Registry communications requiring proof of pre-deposit, failure to cure the defect, and absence on listed dates weighed against restoration. Technical payment difficulties, the COVID-19 period, management changes, and alleged late knowledge of dismissal did not adequately explain the prolonged delay, particularly where professional representation had filed the appeal and Tribunal orders were publicly accessible. Restoration was denied.

Limitation for filing appeals against Orders-in-Original depends on the actual date of communication, not merely the date on which the order was issued. Where delivery before the assessee's asserted receipt date is disputed, the Department must establish service rather than presume communication from issuance. Verification by field formations, after giving the assessee an opportunity to present its position, is required to determine whether the appeals were time-barred. The limitation question was remitted for fresh determination based on the verified communication date.

Revenue appeals before CESTAT are subject to the National Litigation Policy's prescribed monetary threshold. Where the revenue involved is below that threshold, the appeal is not maintainable for litigation purposes and is dismissed without examination of the underlying merits. The stated appeal involved revenue below the applicable threshold and was consequently dismissed.

TDS credit may be allowed where a cash-basis taxpayer reconciles brought-forward and carried-forward credits with Form 26AS entries for the relevant assessment years. Where professional income has been offered to tax and the payer has deducted tax from payments but failed to deposit it with the Government, Section 205 of the Income-tax Act precludes a direct tax demand against the recipient to the extent of tax deducted. Denial of credit in those circumstances would impose tax on income from which tax has already been withheld.

Section 153C assessment of a person other than the searched person requires the six-year assessment block to be reckoned from the date satisfaction is recorded. Assessment years outside that block are invalid unless the relevant amendment is shown to apply. A satisfaction note must also establish that seized documents pertain or relate to the third person; describing documents as "belonging to" that person does not satisfy section 153C(1)(b), as that expression concerns specified assets. Failure on either jurisdictional requirement renders the assessment unsustainable.

Sale-of-goods arm's length price adjustment requires fresh determination where filed transfer-pricing documentation was not considered, because it is material to benchmarking and the taxpayer's functional profile; the adjustment was set aside for reconsideration. Notional interest on associated-enterprise trade receivables cannot be computed in isolation where interest-free trade payables coexist. Computation must account for both receivables and payables and their respective outstanding periods; the interest adjustment was set aside for recomputation. Both transfer-pricing matters require determination on a complete factual record.

Registration under the Rajasthan Public Trust Act, 1959 remained pending when the application for registration under section 12AB was considered. Evidence concerning the genuineness of the assessee's activities also required submission and evaluation. The application was restored for a fresh decision in accordance with law after obtaining the relevant trust registration and producing supporting material. No view was taken on substantive eligibility for section 12AB registration. The section 80G appeal was treated as consequential to the fresh determination.

Approved insolvency resolution plans that expressly extinguish tax payables and receivables for periods before their effective date preclude subsequent survival of those claims. A tax adjustment or disallowance relating to the pre-effective-date period cannot be sustained where it falls within liabilities extinguished by the plan. Tax dues and receivables incorporated into the approved plan likewise cease to survive for that period. The operative effect is to bar pre-effective-date tax claims, including disallowances connected with extinguished liabilities.

Limitation for a final assessment order following Dispute Resolution Panel directions runs under Section 144C(13) from the end of the month in which those directions are received. Upload of the directions to the departmental portal gave the Assessing Officer immediate access and triggered the limitation period; internal processing or delayed viewing could not postpone it. Directions uploaded on 30 September 2024 therefore required completion by 31 October 2024. The final assessment order dated 7 November 2024 was consequently time-barred and struck down in favour of the assessee.

Section 271AAB treats income admitted during a search as undisclosed income where the taxpayer specifies the manner in which it was derived, declares it in the return, and pays the related tax. A substantially higher net-profit rate than in preceding years may support the conclusion that the income would not have been voluntarily disclosed without the search. Where these statutory conditions are met, penalty at the prescribed 10 per cent rate is sustainable.

Tax deducted at source reflected in Form 26AS should not be denied merely because it was omitted from the return of income, where the tax was deducted and deposited on the assessee's behalf and the corresponding income was offered to tax. Rule 37BA should not be applied rigidly to defeat a genuine credit claim; procedural requirements yield to substantive justice. Retaining deducted tax beyond the lawful liability may constitute unjust enrichment and conflict with Article 265. Credit must be granted after verifying entitlement and corresponding income, with refund interest under Section 244A where applicable.

Enhanced penalty for under-reporting under section 270A requires a clearly identified misreporting limb under section 270A(9). Ordinary under-reporting attracts a 50% penalty under section 270A(7), while the 200% rate under section 270A(8) applies only when the under-reporting results from specified misreporting. Because penalty proceedings are independent and penal, the charge must be unambiguous. Mere references to misreporting in assessment proceedings and computation at the enhanced rate do not suffice where neither initiation nor the penalty order identifies the applicable statutory clause. The 200% penalty was therefore quashed as vague and unsustainable.

Penalty for concealment or furnishing inaccurate particulars lacks a substantive basis where reassessment accepts, without further addition or disallowance, the income returned in response to the reassessment notice. Withdrawal of a bad-debt claim and declaration of a reduced loss in that return do not themselves create an assessment addition capable of attracting deemed concealment under Explanation 1. Penalty proceedings are also invalid where the notice retains both statutory limbs without identifying the specific charge. The notice must communicate a precise and unambiguous allegation; failure to specify whether the charge concerns concealment or inaccurate particulars vitiates the proceedings independently.

Absence of a valid jurisdictional notice under Section 143(2) renders the underlying assessment a nullity. This jurisdictional defect may be challenged when the assessment is enforced or relied on, including during collateral penalty proceedings. Because penalty proceedings derive their legal basis from the assessment, a penalty founded on an invalid assessment lacks a valid legal foundation and is non est. The invalidity of the assessment can therefore be raised in the penalty appeal, resulting in quashing of the consequential penalty.

The enhanced leave-encashment exemption ceiling applies to Assessment Year 2021-22 under the relevant notification. The increase is characterised as a beneficial and curative fiscal measure intended to remedy hardship arising from prolonged non-revision of the exemption limit. Such measures warrant liberal construction and may extend to pending assessments unless retrospective application is expressly barred. The notification's stated effective date does not prevent application of the enhanced exemption to the pending assessment, rendering the full qualifying leave-encashment amount exempt.

Penalty proceedings must be initiated within a reasonable period and completed within the prescribed limitation period. The assessing officer's reference to the competent penalty authority, rather than the later issuance of a show-cause notice, triggers the relevant action. Revenue discretion cannot permit indefinite delay because that would defeat the purpose of limitation law. Where initiation is delayed beyond a reasonable period, the doctrine of delay and laches applies, rendering the penalty order and consequential demand unsustainable and liable to be quashed.

Penalty proceedings must be initiated within a reasonable period, even where the limitation provision specifies only the period for their completion after initiation. The initiating step is the assessing authority's reference to the competent penalty authority, not the later show-cause notice. A purposive construction of the limitation framework prevents indefinite delay and excludes unfettered discretion in commencing penalty action. Delayed initiation rendered the penalty order and consequential demand notice unsustainable, resulting in their quashing.

Penalty proceedings commence when the assessing authority refers the matter to the competent penalty authority, not when a show-cause notice is issued. Although Section 275(1)(c) fixes the period for completing penalty proceedings, delay and laches prevent the Revenue from initiating proceedings after an unreasonable delay. The limitation principle therefore restricts any unfettered discretion to defer commencement. On these principles, the delayed penalty order and consequential demand were treated as invalid and quashed in favour of the assessee.

Interest awarded under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsory land acquisition is treated as an accretion to the value of the acquired land and forms part of the enhanced compensation. It compensates for inflation during the period between determination and payment of compensation. Tax may not be deducted at source from this interest component payable with enhanced compensation.

Money-laundering investigation into alleged bank-loan fraud involving DHFL has resulted in the freezing of bank deposits held by Al Jalore Trading FZE under the Prevention of Money Laundering Act. A United Kingdom property was allegedly disposed of through a purported loan arrangement that created an encumbrance to settle an Indian liability. Sale proceeds were credited to Al Jalore Trading FZE's Indian bank account rather than to the registered owner, indicating alleged dissipation of proceeds of crime through a structured foreign-property transaction.