Section 153A assessments are not confined to incriminating material where the period for issuing notice under section 143(2) remained open on the search date, because the assessment was not concluded. Land qualifies as a capital asset when it falls within municipal limits or when agricultural use is not established; the taxpayer bears the burden of proving exclusion as agricultural land. Recorded material may substantiate a cash-source explanation, but prior cash balances and alleged availability with another firm require reliable supporting evidence. Accordingly, the additions for land-sale gains and unsupported cash remained sustainable.

Revision under Section 263 was unsustainable where the apparent share-count mismatch arose from comparing shares issued during the relevant year with cumulative shareholding, and financial records and shareholder particulars substantiated the explanation. Verification of share capital was therefore not deficient on that basis. A direction concerning share premium also could not support revision because it was absent from the show-cause notice and introduced only in the revisionary order. Although revisionary jurisdiction may extend beyond the notice's exact terms, each ground ultimately relied upon requires full notice and opportunity to respond. The original assessment could not be disturbed on either ground.

Revision under section 263 is unsustainable where scrutiny assessment records establish that the Assessing Officer examined the taxpayer's business model, cash deposits, related expenses and e-wallet or recharge transactions. Cash deposits supported by bank records, service-provider accounts and disclosed commission income, and remitted through banking channels for recharge services, do not render the assessment erroneous merely because some agreements lack signatures. Where the Assessing Officer has applied mind to relevant material and adopted a sustainable view, the assessment is not both erroneous and prejudicial to Revenue interests. The revisionary order was therefore set aside.

Returns filed in response to section 153A notices are treated as returns under section 139, permitting revision under section 139(5) before assessment is completed where the revised return is brought to the Assessing Officer's notice. Additional income declared in an earlier section 153A return cannot be sustained solely on a subsequently retracted search statement when the underlying transactions are already recorded and no incriminating material or independent corroboration supports the addition. An uncorroborated admission is not conclusive evidence for making an addition.

Cash deposits collected from small depositors by a bank business correspondent, deposited into its account and remitted to the lead bank after retaining permitted commission, formed part of an established business model. Consistent acceptance of that model and the income arising from it in earlier years supported the explanation for the deposits. In the absence of new material justifying departure from the accepted position, treating the deposits as unexplained money was unsustainable; the cash-deposit addition was deleted.

Verified creditor confirmations, tax returns, bank statements, banking-channel payments and disclosed interest establish the identity, creditworthiness and genuineness of unsecured loans; once this primary burden is met, the source of source cannot be questioned without discrepancies. Interest disallowance does not arise where interest-free funds exceed advances and the advances finance machinery and land adjoining a factory for business purposes. Documentary evidence of director disputes, business disruption, illness and pandemic-related circumstances can establish sufficient cause for delayed filing.

Surrendered sums arising during a survey and recorded in the audited profit and loss account as business income are taxable at normal business rates where the evidence shows only the taxpayer's existing business activities. Classification as unexplained investment under the deeming provisions requires material linking the surrender to an independent, unexplained source of investment. A surrender made during survey, without that evidentiary connection, does not by itself justify taxation as deemed income under Sections 69B and 115BBE.

Concluded or unabated search assessments require incriminating material found during the search and demonstrably linked to the proposed addition; a standalone statement about personal use of luxury cars does not meet that standard. Payments already recorded as loans and advances in audited regular books, with their source reflected and no expenditure claimed, do not satisfy the conditions for unexplained investment. Consideration of such existing material does not attract restrictions on additional evidence before the appellate authority. Undated and unidentified loose-paper entries require independent corroboration and a nexus to actual cash payments before they can support an unexplained-investment addition.

Fresh scrutiny notice under section 143(2) is mandatory after a return is filed in response to section 148; a notice issued earlier cannot meet that requirement, rendering reassessment void for jurisdictional defect. Unsecured loans supported by lender confirmations, tax returns, audited accounts and bank statements satisfy the tests of identity, creditworthiness and genuineness where received and repaid through banking channels. An addition for unexplained cash credits cannot rest solely on investigation reports or third-party statements without lender inquiry, defects in records, corroborative material, disclosure of material, or an opportunity for cross-examination.

Limited-risk distributors performing routine promotion, invoicing, customer support and compliance functions, while holding no valuable intangibles and bearing limited operational risk, should be benchmarked under the Transactional Net Margin Method where it produces a reliable arm's-length result. Royalty agreements pricing content or technology rights not acquired or exploited by the distributor are not reliable comparables for the Other Method. Functional allocations require external comparability and a supportable cost-driver and risk-return basis. Income computation should conform to the correct section 143(1)(a) intimation where an assessment records a higher figure.

Best-judgment assessment for non-filing cannot continue where annual and monthly GST returns disclose the relevant supplies and delayed monthly filing leaves no revenue implication. Annual GSTR-9 disclosure of inward and outward supplies may demonstrate substantive compliance despite late GSTR-3B filing, subject to statutory action for any identified return discrepancy. Rectification of an assessment remains subject to the prescribed limitation period; an application made nearly two years after the assessment was treated as time-barred. Consequently, the non-filer assessment was set aside, while rejection of the delayed rectification request remained undisturbed.

Belated filing of a valid return by a non-filer triggers deemed withdrawal of a best-judgment assessment. The prescribed period for furnishing the return is treated as directory rather than mandatory, so filing beyond that period does not prevent the withdrawal consequence. Tax authorities may still verify the subsequently filed returns and issue a fresh show-cause notice where short-payment is identified. The original best-judgment assessment consequently ceases to operate upon filing of the returns.

Section 138 requires a cheque to be presented within its validity period. Following the merger of Syndicate Bank with Canara Bank, legacy Syndicate Bank cheques remained valid for presentation only until 30 June 2021, after which the former banking codes were permanently disabled. Presentation of such a cheque in 2025 therefore involved an invalid instrument. Dishonour of an invalid cheque does not trigger criminal liability under Section 138, and prosecution based on it would constitute an abuse of process.

Revisionary jurisdiction over an assessment that accepted Form-F declarations under section 6A(2) of the Central Sales Tax Act was unavailable where the same issue had been determined for subsequent assessment years and those determinations were accepted without challenge. Finality of the subsequent-year adjudication required consistent treatment of the relevant assessment year, rendering revision of the accepted declarations unsustainable.

Job-work clearances returned by an independent job worker to the principal manufacturer for further manufacture cannot use the captive-consumption valuation method, because the goods are not consumed by the job worker or on its behalf. Where the prescribed job-work valuation alternatives do not apply, the residuary method requires reasonable cost-plus valuation consistent with Section 4. Assessable value should comprise material cost, processing or conversion charges, and the job worker's profit. This approach excludes differential duty founded on captive-consumption valuation.

Works contracts involving execution of original works are valued at 40% of the gross amount under Rule 2A(ii)(A), rather than the 70% measure applicable to other works contracts. Recorded service-tax payments, including the provider's reverse-charge share, may satisfy the resulting liability. A service-tax demand cannot rest solely on a mismatch between income-tax and ST-3 returns where timing differences arise from accrual accounting and subsequent TDS reporting; books of account and admissible evidence of consideration must be examined. Extended limitation requires evidence of suppression or another statutory ground, and is unavailable where relevant payments and information were disclosed.

Bona fide purchasers of provisionally attached property may obtain release where registered title was acquired for agreed consideration without disclosure of the pre-existing attachment and an identifiable unpaid sale balance remains available for substituted attachment. Although the attachment pre-dated the sale agreement and public notice had been published, the seller suppressed the attachment during proceedings leading to the court-directed conveyance. The property is released to the purchaser, while the Enforcement Directorate may seek attachment of the sale consideration retained by the court-appointed receiver as substituted property.

Regular bail under the Prevention of Money-laundering Act may be justified where prolonged pre-trial detention, a voluminous charge-sheet, numerous witnesses, and the resulting unlikelihood of an early trial conclusion engage the constitutional right to speedy trial. Parity with a co-accused already released on bail may also support relief notwithstanding the statutory twin conditions. Risks of absconding, reoffending, travel, or witness interference may be addressed through stringent conditions, including passport deposit, periodic reporting, travel restrictions, and limits on contact with witnesses.

Security interest under the Insolvency and Bankruptcy Code must arise from a consensual agreement or arrangement, rather than solely from a statutory charge. The 2026 Explanation to the definition of security interest is clarificatory and retrospectively applicable. A lease clause granting priority over unearned increase only upon mortgage sale or foreclosure does not create a present general charge over lease premium, rent, or arrears. Statutory recovery of arrears as land revenue is a recovery mechanism, not a consensual charge; the resulting claims remain unsecured statutory or operational dues.

Continuing guarantee obligations are not extinguished by an arbitral repayment arrangement unless novation, a substituted contract, or an express release is established; such an arrangement does not make the guarantor a co-borrower. A creditor retains standing to invoke a guarantee where no assignment of its independent debt share or full satisfaction is shown. Third-party assumption of liabilities, payments, restructuring by other lenders, or security realisation do not discharge the guarantor absent binding substitution, creditor-led variation without consent, or contractual release. A personal insolvency application filed within three years of default is timely. Disputes over guarantee caps or debt computation do not prevent admission where debt and default are established, subject to crediting recoveries to avoid double recovery.