Broken-period interest on securities held as stock-in-trade is revenue expenditure, while interest disallowance for exempt income requires a proven borrowing-investment nexus. Overseas training of Indian-branch staff falls outside the specified head-office expenditure restriction, and unrealised gains on executory forward contracts lack real-income accrual. Payments between an Indian branch and its head office or overseas branches do not trigger withholding where they are not taxable to the same enterprise. Additional Commissioners are included within the expression Joint Commissioner absent proof of missing Board authorisation. Transfer-pricing analysis may cover permanent-establishment dealings, aggregate closely linked placements, but cannot determine the year of income taxability. Integrated correspondent banking and incidental oversight are not separately remunerable without a distinct transaction or benefit; profit-split analysis requires allocation by relative functions, assets and risks.

Income tax or TDS cannot be deducted from compensation payable for compulsory acquisition of land. This extends to the component forming part of enhanced compensation under Section 28 of the Land Acquisition Act, 1894. No lawful basis exists for withholding any portion of such compensation on account of income tax or TDS, requiring the compensation to be paid to landowners without those deductions.

Prepaid SIM-card and recharge-coupon distribution on a principal-to-principal basis does not create an agency relationship merely because the supplier imposes ownership, customer-documentation, or regulatory-compliance obligations. Distributors purchase products at a discount, independently set resale prices, and earn their margin on resale. Where that margin arises from the distributor's resale price and is neither paid nor credited by the supplier, it is not commission or brokerage requiring tax deduction at source under Section 194H. The tax-withholding mechanism therefore does not apply to the distributor's resale margin.

Section 68 requires an assessee claiming unsecured loans to establish the creditor's identity, financial capacity and the genuineness of the transaction through cogent evidence. Confirmations and payment by cheque alone do not establish creditworthiness where creditors deny advancing the loans or cannot satisfactorily explain their funding sources and preceding cash deposits. Failure to discharge this initial burden supports an addition for unexplained cash credits, and a concurrent factual finding that creditors lacked creditworthiness is not perverse on those circumstances.

Faceless assessment of capital gains cannot treat gross sale proceeds as taxable gains while disregarding documentary material supporting the cost of acquisition, transfer expenses, and reinvestment claims. Sale deeds, acquisition records, legal-expense evidence, and reinvestment documents furnished through the assessment portal require specific consideration. Denial of deductions and reinvestment benefits without identifying deficiencies, conducting enquiry or verification, or giving reasoned consideration is legally infirm. A fresh reasoned assessment, with a personal hearing, is required where the material submitted has not been addressed.

Clause (iv)(b) of Explanation 1 to section 153 treats receipt of a copy of an order setting aside a special-audit direction as the limitation trigger; unlike clause (ii), it does not require a certified copy. A digitally signed order communicated by email or fax was sufficient to start that period. Receipt by departmental authorities by 10 January 2026 meant limitation expired by 13 March 2026. The later special-audit direction, audit report and assessment were without jurisdiction, and returned income stood deemed accepted.

Chit foreman payments made to cure subscriber defaults are treated as debts arising in the ordinary course of the chit business; once written off, separate proof of irrecoverability is unnecessary, and they may alternatively qualify as business loss. Consistent treatment across unchanged assessment years supports deductibility of interest on security deposits, commissions and gifts paid to associated entities. Recurring turnover-based payments for a terminable, non-exclusive and non-transferable logo licence remain revenue expenditure because no intellectual-property asset or enduring benefit is acquired. OD interest remains allowable where surplus own funds exceed interest-free advances.

Tax-refund adjustment constitutes coercive recovery and cannot be used against demands protected by a subsisting unconditional stay. Refunds adjusted against demands for Assessment Years 2016-17 to 2018-19, which were treated as non-collectible, must be reversed with statutory interest. While a stay application remains pending, recovery through refund adjustment is barred; for the Assessment Year 2021-22 demand, retention is limited to 20% under recovery guidelines, with excess adjustment refunded and the balance demand stayed pending appeal.

Standing to challenge a search and seizure authorisation directed at a company belongs to the affected company. An additional director does not obtain a personal cause of action merely by holding that office and therefore cannot invoke writ jurisdiction to contest the authorisation. Any grievance concerning the legality of the search or its authorisation must be pursued by the company.

Sufficient cause for condoning a prolonged delay in re-presenting tax appeals requires a reasonable, plausible and bona fide explanation covering the entire period of delay. General reliance on administrative workload, simultaneous appeals, voluminous records and procedural requirements does not explain sustained inaction. Government departments remain subject to limitation rules and cannot obtain condonation merely because of bureaucratic processes. Consistent treatment is required where delayed appeals arising from the same appellate order have previously not been entertained. Condonation of the Revenue's delay was declined in favour of the assessee.

Wrongful PAN linkage to bank accounts and cash transactions belonging to a company removed the factual basis for attributing the related income to an individual taxpayer. Assessment under best-judgment and faceless-assessment provisions, consequential penalty proceedings, tax demands, and revision could not stand without that attribution. The taxpayer bore no tax or penalty liability for the company's transactions; the assessment, penalties, demands, and revisional action were set aside.

Reassessment of a disclosed long-term capital loss from the sale of immovable property cannot rest solely on reconsideration of material examined during the original scrutiny assessment. Where sale consideration, capital-gain computation, purchase deeds, co-owners' shares and land records were produced and accepted, reopening requires fresh tangible material indicating escaped income. Reopening on the same transactions without such material constitutes a change of opinion and invalidates the reassessment notice and order.

Reassessment under Sections 148 and 148A requires a valid basis to conclude that income has escaped assessment. Disclosure of cryptocurrency sales, purchases, opening and closing stock, and resulting income in the return, reply and reconciliation statement precludes a finding of non-disclosure merely because the return form lacks a separate cryptocurrency reporting head. Because the premise of undisclosed Bitcoin transactions was factually incorrect, the Section 148 notice and Section 148A(d) order were quashed.

Reassessment requires material indicating that income chargeable to tax escaped assessment in the specific assessment year proposed for reopening. Unsecured loans had been obtained and disclosed in the preceding year, while the relevant year's ledger reflected only interest expenditure. The loan amounts cited in the reopening material also did not match the recorded interest amount. Because the alleged loan transactions did not pertain to the year reopened, the reassessment lacked a sustainable factual basis and was unsustainable.

Refund of payments made by a partnership firm towards an individual partner's outstanding income-tax demand is unavailable where fixed deposits and a cheque were voluntarily tendered. A bank attachment, without more, does not establish coercive recovery. Where the revenue authorities were not informed of an alleged change from proprietorship to partnership when payment was made, departmental action is not rendered illegal, erroneous, or arbitrary. Any claim arising from the firm's payment of a partner's tax liability remains an inter se dispute between the partners rather than a basis for refund from the tax department.

Section 107 of the CGST Act confines an appellate authority's power to condone delay to the prescribed outer limit; equitable considerations or constitutional relief in another proceeding cannot enlarge that statutory jurisdiction. Restoration of cancelled registrations pursuant to appellate orders may render a departmental challenge infructuous where undoing the restoration would disturb intervening business and compliance actions, leaving no effective relief. The statutory appeal against cancellation remains independent of revocation under Rule 23: expiry of the portal-based revocation period does not extinguish the right to pursue an appeal.

Section 107 confines an appellate authority's power to condone delay to the statutory outer limit; equitable considerations and constitutional relief under Article 226 cannot enlarge that jurisdiction. Where registration cancellation orders have been implemented through restoration of registration and taxpayers have resumed business and compliance, a departmental challenge may become academic because annulment would disrupt intervening transactions. The appeal remedy under Section 107 operates independently of the revocation procedure under Rule 23, so inability to file a revocation application after the prescribed period does not extinguish the right to challenge cancellation in appeal. Restored registrations and their consequential legal effects remain undisturbed.

Customised road restoration requested by a business entity to facilitate a pipeline project constitutes consideration for a taxable service, rather than a sovereign public-road function or unilateral compensation. Non-supply and exemption treatment are unavailable, including where exemptions exclude Government or local-authority services supplied to business entities. The recipient bears GST under reverse charge where no forward-charge tax payment is established; revenue neutrality or alleged double taxation does not support a refund claim. Electronic portal-based proceedings remain valid without a physical DIN where the notice adequately states the factual and legal basis and the recipient suffers no prejudice, preserving the rejection of refund relief.

GST transit requirements require goods in movement to be accompanied by prescribed documents, including a tax invoice and a valid e-way bill. Manual invoices produced more than three months after interception, without electronic or contemporaneous corroboration, do not establish lawful inward supply, retrospectively cure undocumented movement, or rebut the presumption of intent to evade tax. Where an amount is recovered for release of the same goods in detention proceedings, it must be adjusted against the demand arising from the identical goods and cause of action, as parallel proceedings for that identical cause cannot be maintained.

Unaccounted goods detected during a survey must be treated as supplies for tax determination under Sections 73 or 74, pursuant to the record-keeping and deemed-supply framework in Section 35. Excess or unaccounted stock found at business premises cannot be taken directly to confiscation proceedings under Section 130(2), including consequential fine and penalty. Tax liability must instead be determined through the prescribed statutory procedure.