Substituted service of an adjudication order through the prescribed notice-board procedure starts the appeal limitation period when postal delivery fails. Section 37C of the Central Excise Act, 1944 governs service, while Section 85 of the Finance Act, 1994 governs the appeal period. Placement on the notice board may be recorded in a panchnama after an order sent to the recipient's communication address is returned with a remark that the recipient has left. An appeal filed beyond the applicable limitation period following valid substituted service is time-barred.

Under the Prevention of Money Laundering Act, 2002, a Special Court may take direct cognizance of a money-laundering complaint without hearing the accused beforehand; the special procedure prevails over inconsistent general criminal procedure. The savings provision of the Bharatiya Nagarik Suraksha Sanhita, 2023, preserves the earlier procedural regime where the investigation began before the new law commenced. A coal-block allocation letter is not itself proceeds of crime, but gains obtained by using the allocation, including through preferential share issues, may qualify. An assessment at the summoning stage does not determine charges or final liability.

The proviso to Section 223(1) of the BNSS requires an opportunity of hearing, which may be given through the appellant's authorised representative. For the hearing before the Special Court, the authorised representative must appear so that the opportunity can be provided. No further notice will be issued to the appellant.

Complainants with a genuine legal grievance may appeal a final disciplinary order imposing punishment, including on the ground of inadequate punishment, under section 220 of the Insolvency and Bankruptcy Code, 2016. Closure of a complaint for lack of a prima facie case is subject to review under the 2017 complaint-handling regulations, not statutory appeal, which does not extend to procedural or interlocutory decisions. A complainant whose complaint initiated the disciplinary proceedings may seek impleadment as a proper party in the service provider's appeal, but need not be impleaded automatically. A stakeholder with an unrelated complaint lacks the direct interest required for impleadment.

Section 263 of the Income-tax Act, 1961 requires an assessment to be both erroneous and prejudicial to the interests of revenue before revisional jurisdiction can be exercised. Revision requires findings identifying the relevant error and resulting prejudice; merely reproducing a show-cause notice does not supply those findings. A taxpayer's failure to respond to the notice, by itself, cannot justify revision or substitute for the required findings.

Section 68 places the primary burden on the assessee to establish investors' identity and creditworthiness and the genuineness of share application transactions. For one investor, an unverified loan source and material indicating a non-genuine loan were relevant. Depreciation was to be computed using invoices and bills already on record, despite a Rule 46A objection concerning the assessing officer's opportunity to examine them. Royalty differences were addressed through reconciliation, examination of ledger folios and account-payee cheque payments. Section 35D permits amortisation of qualifying preliminary expenses, with one-fifth deductible.

Section 272A provides for penalties for non-compliance with specified statutory notices, subject to reasonable-cause protection under section 273B. Lack of qualified personnel or knowledge of tax obligations is insufficient where there is no evidence of bona fide efforts to comply or communicate difficulties. Multiple assessment and penalty notices received no response, including after service on the society's secretary. Despite a claimed lack of opportunity, the penalty was sustained.

An addition for unexplained cash credits in an unabated assessment under section 153C must be supported by specific seized material relevant to that addition. The date on which satisfaction is recorded is treated as the date of search for determining the assessment's status. Where the assessment was unabated on that date, the absence of identified seized material indicating unexplained cash credits leaves the addition unsupported.

Section 115BBE of the Income-tax Act, 1961, applies only to transactions on or after 1 April 2017. The remaining addition for unexplained cash deposits is assessed under the normal provisions. Documented cash withdrawals and cash availability are relevant to relief from an addition under Sections 68 or 69, even where the explanation has shortcomings. Relief may reduce the addition without removing it entirely.

Technical failure of the official provident fund payment portal precludes disallowance of employees' contributions deposited after the prescribed deadline where timely payment was attempted but prevented by circumstances beyond the taxpayer's control, and payment was made once the portal resumed functioning. The doctrine of impossibility applies to the resulting delay despite the deposit deadline under the Income-tax Act. Acceptance of the payment without interest or penalty supported the evidence of a technical glitch.

Taxation of a private discretionary trust at the maximum marginal rate does not automatically require surcharge at the highest rate. The applicable Finance Act prescribes surcharge slabs separately from the income tax rate, and surcharge is computed by reference to those slabs. This distinguishes the income tax rate used to calculate the trust's tax from the surcharge applied to that tax.

Penalty for furnishing inaccurate particulars under section 271(1)(c) of the Income-tax Act, 1961 cannot survive when the underlying quantum addition is deleted in the assessment proceedings. Where the penalty is based on an addition under section 43CA, deletion of that addition removes the basis for the penalty, making it unsustainable.

For deposits of specified bank notes with a cooperative credit society during demonetisation, section 68 concerns whether the amounts are unexplained cash credits. Furnishing relevant member identification and KYC details shifts the onus to the revenue under the applicable precedent. An addition cannot rest solely on the society's alleged lack of authority to accept demonetised notes where relevant depositor particulars have been furnished.

Interest earned by a co-operative credit society on deposits with co-operative and scheduled banks qualifies for deduction under section 80P(2)(a)(i) when the deposits consist of income derived from its business. Such interest is attributable to the society's business. This treatment distinguishes investment of the society's own business income from investment of retained amounts belonging to members.

Revisional jurisdiction requires an assessment to be both erroneous and prejudicial to revenue; disagreement with a plausible view adopted after enquiry is insufficient. Excess stock disclosed during a survey may be treated as business-derived rather than unexplained income where enquiry supports its business source. Records of tax deduction and deposit on contract payments, and job-work payments within applicable deduction thresholds, are relevant to review of tax compliance. Consistent revenue treatment of right-of-way expenses in earlier years, without a material change in facts, is also relevant. Lack of enquiry is distinct from inadequate enquiry.

Share capital and share premium are examined under section 68 for the subscribers' identity and creditworthiness and the genuineness of the transactions. Bank records, source certificates, financial statements and returns can support these requirements. Failure to respond to information notices alone is insufficient to disregard supporting evidence or sustain an unexplained cash-credit addition when all three requirements are established.

Revisional proceedings initiated against a deceased assessee are a nullity, making a revision order passed against that person invalid. Proceedings initiated after death are distinguished from proceedings begun during the assessee's lifetime and continued against legal heirs. Where the assessee had died before the assessment and revision orders were made, and the legal heir had informed the tax authorities of the death, the revision could not stand.

Bank interest received by an association was assessed separately as income from other sources, and expenditure was disallowed under section 57 of the Income-tax Act, 1961. The association's accounts included bank interest and member contributions but showed an overall loss, raising the issue of loss set-off under section 70. The separate addition of bank interest was to be deleted and income recomputed in accordance with the return.

Contingent excess interest spread from securitised debts is taxable as it accrues, not upfront based on an estimated present value, where its receipt and amount depend on collections and payments under the agreed waterfall. The accrual method is assessed against real income and prudence principles and Accounting Standard 9. Amortised premiums on foreign currency forward contracts hedging foreign currency borrowings are allowable expenditure, not speculative losses. The claim for 100% depreciation on temporary structures remains subject to verification of expenses.

Cash deposits in specified bank notes during demonetisation cannot be treated as unexplained income solely because of the form of deposit when supported by identified business receipts. The relevant tax framework covers unexplained cash credits under Section 68 and taxation under Section 115BBE of the Income-tax Act. Audited accounts, customer ledgers, invoices, bank statements, VAT returns, sales-tax records and customer identification can support the source of deposits. Transactions in specified bank notes before the appointed date were not prohibited under the Specified Bank Notes (Cessation of Liabilities) Act, 2017, provided the source of deposits could be established.