Section 270A requires the competent authority to direct, during proceedings under the Income-tax Act, that a person is liable to penalty for under-reporting income. Neither the assessment order nor the consequential order giving effect to the appellate order recorded initiation of penalty proceedings. An appellate observation that proceedings had been initiated was factually incorrect. In these circumstances, the penalty order was void ab initio and the penalty was liable to be deleted.

Reassessment notices for assessment years up to 2021-22 remain governed by the earlier limitation period under the first proviso to section 149(1)(b); accordingly, a notice for AY 2015-16 issued after expiry of its six-year period is time-barred, rendering the consequential section 147 assessment unsustainable. Where a notice for AY 2016-17 is issued more than three years after the end of that year, section 151(ii) requires prior approval from the Principal Chief Commissioner or another specified authority. Approval from a Principal Commissioner is insufficient, invalidating the reassessment and consequential assessment.

Reassessment proceedings initiated against a company dissolved through amalgamation before the notice was issued are jurisdictionally defective where the Assessing Officer had been informed of the amalgamation. A notice issued to the non-existent entity, and the consequential assessment, are void ab initio. A best-judgment assessment cannot cure this foundational defect, so reassessment proceedings cannot be sustained against the dissolved company.

Registration under section 12AB depends on satisfaction as to an entity's objects and the genuineness of its activities, supported by documents prescribed under Rule 17A(2). Non-compliance with electronic notices may warrant fresh consideration where an unrebutted affidavit establishes a bona fide inability to access them, including because of a trustee's age, health or absence. The registration application is to be reconsidered after the applicant furnishes the requisite documents and complies with notices.

Section 14A read with Rule 8D(2)(iii) requires the administrative-expense disallowance to be computed using the average value of investments that actually yielded exempt income during the relevant year. Including all investments shown in the balance sheet, irrespective of whether they generated exempt income, is inconsistent with this approach. The disallowance should therefore be recomputed by excluding investments that did not yield exempt income during the year.

Cash deposits stated to represent turnover from an eligible food-grain business were considered under the presumptive taxation framework rather than as unexplained investment. Where comparable turnover in the succeeding year had been accepted for presumptive computation and turnover was not questioned for either year, income was computed at the 8% presumptive margin. This treatment replaced the unexplained-investment addition and produced income below the taxable threshold on the stated facts.

Cash deposits comprising specified bank notes are not assessable as unexplained money under Section 69A where customer collections for electronic-payment facilitation are supported and their source is explained; dealings before 31 December 2016 were not prohibited. Bank credits demonstrably attributable to another taxpayer's money-transfer business, where related commission has been taxed there, must be excluded to avoid double taxation. Commission for the taxpayer's own electronic-payment facilitation business is to be computed at the evidence-supported 2.5% rate rather than 8%, with eligible TDS credit.

Industrial Promotion Assistance granted for capacity expansion, modernisation and marketing improvement is characterised under the purpose test by its object rather than its sales-tax-based quantification; it is therefore a capital receipt outside taxable income. Railway-siding costs are revenue expenditure where the taxpayer does not own the sidings, subject to confirming that depreciation has not been claimed. Where own funds cover investments, no interest disallowance arises for exempt-income investments. Indirect-expenditure disallowance is confined to investments that actually generated exempt income during the relevant year.

Pre-reassessment procedure requires a show-cause notice to provide at least seven and no more than thirty days for a response. A notice allowing six days does not meet the statutory minimum, which operates as a due-process safeguard. The jurisdictional determination to issue a reassessment notice must also be a reasoned speaking order that considers the available material and the assessee's response. A blank determination contains neither a decision nor reasons and cannot support reassessment jurisdiction or consequential assessment proceedings.

Recorded bullion-sale cash deposits during demonetisation were explained where regular cash books, sales registers, stock records, audited accounts, purchase records and VAT returns substantiated the sales, and neither stock movement nor sales disclosures were disputed. Section 69A did not apply because sale proceeds already recorded, credited and offered to tax could not be reassessed as unexplained money without double taxation. Unsupported suspicion concerning the timing or volume of sales could not override the documentary trail establishing the source of deposits. The unexplained-money addition was deleted.

Disclosure of additional income in a revised return only after departmental detection of undisclosed sales during survey proceedings does not negate prior concealment; penalty for concealment remained sustainable. A corporate assessee seeking condonation of delayed appeal filing must show bona fides, diligent follow-up and sufficient cause covering the entire delay. Mere attribution of delay to tax advisers, without convincing evidence of oversight or misleading conduct, does not discharge that responsibility. The unexplained delay therefore precluded appellate relief independently of the merits-based justification for the concealment penalty.

Capital work-in-progress not charged to the profit-and-loss account is capital expenditure and cannot support a percentage disallowance without evidence of an inadmissible charge. Audited books not rejected cannot support ad hoc expense disallowances based solely on increased expenditure or alleged missing bills. Likewise, supplier non-filing or non-response to statutory notices does not itself disprove purchases; estimated purchase additions require rejection of books under the applicable statutory mechanism. Tax additions cannot rest on presumption, ad hoc percentages, or supplier non-response where revenue expenditure is not claimed or accounts remain unrejected.

Revisionary jurisdiction over an assessment requires the order to be both erroneous and prejudicial to Revenue interests. Lender-wise particulars, confirmations, bank statements, tax returns, balance sheets and explanations obtained during assessment established that inquiries into unsecured loans had been made. An assessment order need not reproduce every item of material considered; absence of detailed discussion does not prove lack of inquiry. A completed inquiry cannot be revised merely because a deeper inquiry or different view is preferred, since inadequate inquiry differs from no inquiry. Subsequent repayment of most loans further supported transaction genuineness. The revision order was quashed.

For reassessment notices treated as deemed notices under section 148A(b), a fresh notice under section 148 must be issued within the limitation period surviving under the Income-tax Act read with the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. On the stated computation, that period expired on 13.06.2022. The notice under section 148 and the order under section 148A(d), both issued on 29.07.2022, were therefore time-barred, invalidating the notice and consequential reassessment proceedings.

Modification or body-building of a fully built motor vehicle does not itself establish manufacture or excisability; the process must be assessed under the statutory definition of manufacture and the relevant tariff note, including whether it involves body-building on a chassis. Exemption eligibility consequently requires fresh determination. Extended limitation and evasion penalties require fraud, wilful misstatement, suppression, or deliberate contravention intended to evade duty. Registered taxpayers who disclosed clearances and exemption claims in returns, scrutiny, and audits do not incur those consequences merely through non-payment or a mistaken legal position. Any duty liability remains confined to the normal limitation period, and personal penalty requires proven knowing involvement with confiscation-liable goods.

Maximum packing speed determines capacity-based duty liability for pan masala packing machines. The statutory scheme treats the number of machines and their maximum operable packing speed as relevant to capacity determination, deemed production and duty. Although a fresh declaration may follow subsequent changes, alteration of a machine cannot reduce its maximum-speed category where the same goods continue to be packed at the same retail sale price. A machine previously operated at 1,000 pouches per minute remained within the 751 pouches per minute and above category; reduced actual speed did not support a reduced-speed declaration or lower duty classification.

Governmental services involving registration, testing, calibration, safety checks or certification required by law qualify for service-tax exemption. Licences, permissions and registrations satisfy that requirement where they are indispensable to lawfully carrying on the business; fees paid for them are consequently exempt from service tax. Separately, a service-tax demand under the Reverse Charge Mechanism cannot be sustained on limitation where any tax paid would have been immediately available as CENVAT credit. The levy on governmental fees therefore fails on both exemption and limitation grounds.

Reverse-charge service tax payable by recipients of services from abroad under Section 66A could be discharged using permissible CENVAT credit. Because such credit utilisation was permitted, the conditions for invoking the extended limitation under the proviso to Section 73 were absent. The limitation governing recovery of the principal service tax also governed consequential interest. Accordingly, recovery of interest beyond the normal limitation period was barred, and the interest demand could not be sustained.

Service-tax demand based on a departmental sales-turnover computation lacks support where the acknowledged VAT audit report records a different turnover and VAT payment, while no documentary material supports the lower figure adopted. The resulting assumed taxable-service component is unsustainable. Residual taxable-service receipts of Rs. 9,32,999 fall within the Rs. 10 lakh exemption threshold under Notification No. 33/2012-S.T. for services chargeable under Section 66B of the Finance Act, 1994. No service tax is payable on those residual receipts, and the adjudged liability lacks a sustainable basis.

Extended limitation for service-tax recovery under section 73 requires established suppression of facts, wilful misstatement, fraud, or comparable conduct. Disclosure of relevant receipts and taxable transactions in VAT and ST-3 returns, particularly where those records were considered when the proposed demand was dropped, does not establish such conduct. Recovery is consequently confined to the normal limitation period. The service-tax demand for 2015-16 was therefore barred by limitation.