Section 36(1)(va) permits consideration of a provident-fund contribution deposited after the prescribed due date where a demonstrated payment-portal malfunction made timely payment impossible. Relief under the doctrine of impossibility depends on the assessee furnishing documentary evidence that the portal glitch caused the delay; an unsupported assertion is insufficient. Where evidence is absent, the claimed technical failure requires limited verification. Deduction is available if verification establishes that the delayed deposit resulted from the portal malfunction.

Jurisdiction for a best-judgment assessment under Section 144 must be exercised by the competent assessing authority. Where the taxpayer resided and conducted proprietary business in Aizawl, and the disputed cash deposits were held in an Aizawl bank account, no material supported the Delhi officer's assumption of jurisdiction. The assessment was therefore treated as without jurisdiction and non est, resolving the jurisdictional issue in the taxpayer's favour.

Rule 46A does not require a first appellate authority to obtain a remand report in every tax-credit matter. Where tax-credit claims have been examined and verified using material and documents on record, the appellate authority may either call for a report from the Assessing Officer or decide the claims directly. Its co-terminus powers permit grant of verified tax-credit relief without a remand report, and the absence of such report alone does not justify interference with that relief.

Fixed-asset investments and their sources recorded in audited books and the balance sheet cannot be treated as unexplained absent a valid basis to reject those records. Additions based solely on a demand for separate explanation are therefore unsustainable. Eligible payments reflected in audited financial statements likewise support a deduction claim unless there is a basis to disregard the recorded entries; disallowance for alleged lack of substantiation is unjustified. Assessed income must be recomputed after removing the fixed-asset additions and allowing the claimed deduction.

Penalty for furnishing inaccurate particulars is not sustainable where a revenue-expenditure claim is fully disclosed, its genuineness is undisputed, and disallowance follows only from its characterisation as capital expenditure. A bona fide claim under Section 37, involving a legal difference over capital-versus-revenue treatment, does not by itself establish inaccurate particulars under Section 271(1)(c). The penalty was therefore not sustainable.

Section 12A(1)(ba)'s requirement to file a return within the due date under Section 139(1) as a condition for exemption under Section 11 applies prospectively from Assessment Year 2018-19. It does not govern Assessment Year 2017-18. Accordingly, delayed filing, including filing in response to a reassessment notice, cannot by itself defeat a Section 11 exemption claim for that earlier year. The exemption remains available in accordance with law despite belated return filing.

Electronic transmission of a reassessment notice must occur within the statutory limitation period: generation and digital signature before the deadline do not constitute delivery where the electronic record is sent afterwards. Under the electronic-service framework, delayed transmission renders the foundational notice time-barred and the consequential reassessment void. Because revisionary jurisdiction requires a valid assessment order, revision cannot operate on a non est reassessment order.

Additional evidence filed in appeal should not be rejected solely because Rule 46A was not expressly invoked. Where an addition arose from non-compliance during assessment, substance should prevail over a procedural omission to cite the rule. Fair opportunity requires admission of the evidence, reconsideration of the matter, and readjudication after hearing.

The presumption for impounded documents attaches to the person from whose possession or control they were found; additions against a firm or other persons require independent corroborative evidence. Diary entries predating the firm, absence of commercial production, prior assessment in the individual's hands, and implausible agreement terms did not support additions for unexplained cash, land investment, or purchases. Where entries identify separate contributors, only the identified individual's cash contribution may be assessed, subject to telescoping against the finally determined share of unaccounted income. Separate land-payment and purchase additions were deleted as duplicative or unsupported. Residual unexplained jewellery and cash additions remained sustainable because their sources were not established.

Notice under section 148 issued after expiry of the surviving period available under the applicable reassessment framework and extended limitation regime invalidates the reopening and any revision founded on it. For section 263, reassessment initiated specifically to examine an alleged on-money payment constitutes enquiry where that examination is evidenced by the order under section 148A(d). Mere absence of discussion of the issue in the reassessment order does not, by itself, establish that the order is erroneous and prejudicial to the interests of the Revenue under Explanation 2 to section 263. Revisionary action cannot rest on a time-barred reopening or an unsubstantiated allegation of lack of enquiry.

Reassessment beyond the normal limitation under Sections 148 and 149 requires assessee-specific material showing escaped income at the prescribed threshold, represented by a qualifying asset, expenditure, or book entry. Pooled seized data relating to group entities, without entity-wise attribution or net-income analysis, does not meet those jurisdictional conditions. Where material is seized from another person, bypassing Section 148A also requires compliance with applicable statutory requirements. Approval under Section 151 must be independently considered rather than mechanical. Reopening after prior proceedings were closed on the same material requires fresh information; otherwise, the renewed notice lacks jurisdiction.

Internal TNMM should be preferred over external comparables where associated-enterprise and independent-party transactions involve comparable products, functions, assets and risks. Segmental financials need not be separately audited if reasonably prepared, reconciled with audited books and supported by a consistent allocation methodology. Invoice-level sales allocation, reasonable allocation keys for common expenses, and direct allocation of expenses exclusively relating to non-associated-enterprise sales support reliability. In the absence of identified defects, arbitrary allocations or profit shifting, a higher associated-enterprise segment margin supports arm's-length pricing and deletion of the transfer-pricing adjustment.

Income-tax reimbursement recoverable by a central generating company from beneficiaries forms part of electricity tariff. The Central Electricity Regulatory Commission has jurisdiction under the tariff framework to determine beneficiary objections to the amount claimed, with applicable regulations allowing direct recovery and an application for objections. Tariff regulations and contractual arrangements remain binding unless challenged as ultra vires. Re-determination, limitation, quantification and supporting evidence require factual adjudication before the specialised statutory forum, where beneficiaries may raise objections. That process provides an opportunity to be heard and meets natural-justice requirements.

Reassessment notices issued during an extended period are treated as deemed notices under Section 148A(b). Time from the deemed notice until information is supplied and the assessee's response period expires is excluded for limitation purposes. A fresh notice under Section 148 must nevertheless be issued within the limitation period remaining under the Income-tax Act read with the relaxation legislation. Issuance after the surviving deadline renders the reassessment notice time-barred and invalid, with consequential proceedings liable to be quashed.

Effective service of GST show-cause notices requires more than portal upload where a taxpayer does not respond. Although portal upload is a recognised method of service, officers should consider the circumstances and use alternative modes available under the GST law, preferably registered post, instead of issuing repeated portal communications and proceeding ex parte. Notice must genuinely enable participation, and an assessment made without an effective opportunity to respond or a personal hearing violates principles of natural justice and is invalid.

A one-time, interest-free working-capital loan of Rs. 50,000 per barn is approved for FCV tobacco growers in Andhra Pradesh under the Interest-Free Working Capital Assistance Scheme. Covering about 44,000 growers, the assistance is proposed to be delivered through direct benefit transfer. It is intended to provide liquidity for household requirements, institutional loan repayment and crop inputs, while reducing dependence on private borrowing.

Each auction carries a non-competitive bidding facility, under which five per cent of the notified amount is reserved for specified retail investors. The Government may modify indicated amounts, issuance periods and maturities, and may issue instruments with non-standard maturities, floating-rate bonds or inflation-indexed bonds, having regard to governmental requirements, market conditions and other relevant factors. It may retain additional subscriptions through a greenshoe option and conduct switch or buyback auctions of dated securities.

Government market borrowing for the second half of FY 2026-27 is to be raised through weekly auctions of dated securities, including Sovereign Green Bonds, across maturities from 3 to 50 years. Debt-management measures include switching and buyback operations to smooth the redemption profile and a greenshoe option for additional subscriptions. Treasury Bills are to be issued through weekly auctions in 91-day, 182-day and 364-day maturities. The Ways and Means Advances limit is fixed to address temporary mismatches in government accounts.

Margin earned from purchasing and reselling airline cargo slots at agreed rates constitutes trading income rather than consideration for Business Auxiliary Service where the purchaser acts independently and bears the potential profit or loss. This differs from general sales agency arrangements, in which commission is payable for agency services and service tax applies to that commission. Where no commission is payable and cargo space is acquired for resale on a principal-to-principal basis, the purchase-sale margin is not taxable under Business Auxiliary Service.

Preferential tariff claims must follow the Rules of Origin under the relevant trade agreement, which prevail over CAROTAR, 2020 in case of conflict. Under the India-UK CETA, a valid Origin Declaration supports preferential treatment without Form-I at the Bill of Entry stage. Origin-related information may be requested only where justified by risk-based checks and reason to doubt compliance. Earlier preference denials may apply to subsequent identical goods only after allowing the importer to furnish additional origin information.