Construction of a complex, building or part thereof intended for sale is brought within the amended service description where the amount charged includes the value of land or an undivided share of land. Transactions are excluded where the entire consideration is received after issuance of the required completion certificate or after first occupation, whichever is earlier. The amendment is deemed effective from 20 October 2023.

Rural-branch status for the provision for bad and doubtful debts depends on the population of the relevant place under the latest published preceding census, not merely on inclusion within a larger urban area. RBI census-based branch classification supports the claim. Net investment depreciation is allowable where securities are measured under RBI guidelines and ICDS VIII, with only category-wise net depreciation claimed. Unclaimed stale demand-draft balances remain liabilities to drawees and do not become income while claims remain payable and balances are transferable to the prescribed RBI fund. Ex-gratia employee payments qualify as business expenditure. Rural bad-debt recoveries require verification, while the non-rural bad-debt claim requires fresh merits adjudication.

Banking tax computation allows net depreciation on restructured equity and preference shares where valuation follows RBI guidelines. Appellate enhancement cannot disallow depreciation on security receipts that was not examined in assessment, as it would introduce a new source of income. Bad-debt and qualifying technical write-offs on non-rural advances need not be adjusted against the rural-advance provision. Section 14A and Rule 8D do not produce further expenditure disallowance for banks' stock-in-trade securities. Stale draft balances and advance receipts remain liabilities rather than taxable income. Rural-branch provision deduction uses month-end aggregate average advances, while business ex-gratia payments are deductible.

Statutory penalties imposed for contraventions of the Banking Regulation Act are not deductible as business expenditure where the taxpayer does not establish that the levy is compensatory; absence of prima facie money-laundering evidence does not alter the statutory character of the penalty. The payment is therefore barred by Explanation 1 to section 37(1). The book-profit computation mechanism under section 115JB does not apply to a nationalised bank, following the statutory framework and the Finance Act 2012 amendment. Accordingly, the penalty disallowance stands, while the bank remains outside the minimum alternate tax regime.

Final assessment orders issued after Dispute Resolution Panel directions must be passed within one month from the end of the month in which those directions are received under Section 144C(13). Where the directions were issued in January 2022, digital authentication of the final order and demand notice only in July 2022 did not meet that time limit. As Section 144B(6) requires digital authentication for an assessment order to take effect, the delayed authentication rendered the final assessment order time-barred and invalid.

Deposits assessed as unexplained money required fresh adjudication because the assessee had not responded to assessment notices or supplied relevant details to the Assessing Officer or appellate authority. Adequate opportunity to explain the nature and source of the deposits, and to present defences, was considered necessary in the interest of justice. All issues concerning the deposits were restored to the Assessing Officer for reconsideration after providing an adequate hearing.

Unexplained-investment addition for land acquired in another person's name requires material establishing that the assessee funded the purchase. Registered sale deeds identified the named purchaser and recorded receipt of consideration from him, while his statements attributed the funds to plot-sale proceeds and past savings without linking the assessee. As the investment was also assessed substantively in the purchaser's and connected company's hands, no basis remained to sustain the same addition against the assessee. The addition was therefore deleted.

A specifically raised legal challenge to a penalty for alleged contravention of the cash-loan acceptance restriction cannot be treated as a general ground and left undecided by the first appellate authority. Where reassessment proceedings on the same information were dropped after the amount was treated as a loan for penalty purposes, the legal ground requires adjudication on its merits. The assessee must be given a reasonable opportunity to present supporting material on that ground and all other grounds. Fresh adjudication by the first appellate authority is required.

Registration applications under sections 12AB and 80G(5) were rejected for non-compliance without considering submissions uploaded before the e-filing window closed. Although the response to a later notice was delayed, the material was available on record when the rejection order was made. The applications required fresh examination on merits after considering the uploaded submissions and any further material required. The rejection under section 12AB and the consequential rejection under section 80G(5) were set aside for a fresh decision after reasonable opportunity to the assessee.

Interest income earned by a co-operative housing society on deposits with co-operative banks is treated as eligible for deduction under Section 80P(2)(d), which applies to interest or dividend income derived by a co-operative society from investments with another co-operative society. Co-operative banks in Maharashtra are recognised as co-operative societies for this purpose. Accordingly, where a co-operative housing society earns interest from deposits placed with such banks, that income qualifies for the Section 80P(2)(d) deduction.

Interest expenditure incurred from borrowed funds used for business purposes is deductible under profits and gains of business or profession where the claim is undisputed and unsupported by contrary material. A legitimate deduction claim may be considered at the appellate stage even if it was not made through a revised return. An unexplained-investment addition relating to agricultural land requires verification where civil disputes, instalment payments and subsequent payments may affect the assessee's explanation; the claim should be reconsidered after allowing further evidence.

Unsecured loan credits under Section 68 require the assessee to establish the creditor's identity, creditworthiness and the genuineness of the transaction on a prima facie basis, after which the burden shifts to the Revenue to disprove it. Loan approval and agreement records, RTGS receipt and repayment entries supported the transaction. Reliance on a lender representative's statement without allowing cross-examination, particularly where it was recorded at the assessee's premises, could not sustain an adverse inference. The loan credit was therefore not treated as unexplained and the addition was deleted.

Expenditure previously disallowed for non-payment of tax deducted at source becomes deductible in the previous year of payment under the proviso to Section 40(a)(ia), subject to verification of tax payment and supporting expense records. A disparity between the expenditure amount and tax paid does not alone justify rejecting the claim. The deduction requires fresh verification and adjudication. Set-off of brought-forward losses and unabsorbed depreciation, where not adjudicated in first appeal and denied in tax computation, requires de novo determination after a reasonable opportunity of hearing.

Documented listed-share transactions executed through the stock exchange, supported by contract notes, demat-account entries and banking-channel payments, established their genuineness. Holding the shares for more than one year, coupled with the absence of cogent material rebutting the evidence or linking the assessee to alleged accommodation-entry operators, discharged the assessee's burden of proof. Sale proceeds therefore could not be treated as unexplained cash credit, and the related estimated commission addition as unexplained expenditure could not be sustained.

Section 144C(13) of the Income-tax Act requires the Assessing Officer to pass the final assessment order within one month from the end of the month in which Dispute Resolution Panel directions are received. Where the directions were received by email on 28 September 2024, the statutory period expired on 31 October 2024. A final assessment order dated 3 December 2024 was therefore time-barred, resulting in the limitation issue being decided in favour of the assessee.

External development charges paid by a developer to the Haryana Urban Development Authority constitute contractual payments subject to tax deduction at source under Section 194C. Applying the jurisdictional High Court ruling favouring the Department, failure to deduct tax on those charges results in the payer being treated as an assessee in default under Sections 201(1) and 201(1A), with consequential liability for the applicable default provisions.

Personal insolvency proceedings raised a challenge to the National Company Law Tribunal's authority to constitute a five-member bench after a split verdict. The challenge contended that the mechanism for differing views permits reference to another member or members, but does not authorise a five-member bench. The larger bench stayed the third member's order, restricted asset alienation, and suspended an order permitting settlement of personal-guarantee claims. The dispute concerned the validity of that bench, the split-verdict reference procedure, repayment-plan eligibility, and pending creditor appeals.

Activities or transactions for consideration between a person other than an individual and its members or constituents are retrospectively treated as supplies between separate persons. Input tax credit requires supplier-furnished outward-supply invoice or debit-note details to be communicated to the recipient. Annual returns may include self-certified reconciliation statements, while interest on delayed returns generally applies only to tax paid through the electronic cash ledger. Detention and seizure provisions are recast around penalty payment, notice and order timelines, disposal of goods on non-payment, and a pre-deposit requirement for appeals.

Clarification advance-ruling application was treated as infructuous and withdrawn after the applicant and its authorised representative failed to attend repeated personal-hearing notices. The non-attendance was construed as lack of interest in pursuing the requested clarification. The application was consequently dismissed as withdrawn, without any clarification being issued.

Repeated notices for personal hearing were issued in GST advance-ruling proceedings on a clarification application. Neither the applicant nor an authorised representative attended the hearings. Continued non-appearance was treated as lack of interest in pursuing the clarification request, and the application was regarded as infructuous and dismissed as withdrawn.