Penalty notices for concealment of income or furnishing inaccurate particulars must specify the exact charge by striking out the inapplicable statutory limb. Retaining both alternatives without clarification fails to give the taxpayer clear notice of the allegation and impairs an effective defence. Such ambiguity vitiates initiation of penalty proceedings. The defect applied to both assessment years, rendering the penalty notices invalid and the penalties unsustainable; the penalties were deleted.

Revisionary jurisdiction cannot be exercised on an incorrect factual premise where the assessment record shows that the Assessing Officer examined and accepted the explanation for cash deposits. The revision relied on a deposit figure inconsistent with departmental bank details, while the assessment had already obtained information, considered the taxpayer's response and made no addition. The alleged inadequate enquiry was therefore factually unsustainable, rendering the revision order without valid jurisdiction and liable to be quashed.

Reassessment based on alleged accommodation-entry information requires the Assessing Officer to independently form a reason to believe that taxable income escaped assessment. Investigation material alone is insufficient where the assessee's explanation and records are not properly examined. Treating a share issue as unsecured loans, despite contrary material, and relying on factual errors undermines the reopening. Where the income forming the recorded basis for reopening is explained or does not survive, another income identified during reassessment cannot be independently assessed. The reassessment is therefore void and consequential additions cannot survive.

Section 153A assessments cannot sustain additions for alleged unexplained construction investment where the search yields no incriminating material. Construction expenditure recorded in balance sheets, with stated funding sources and no admission of undisclosed investment, cannot be treated as unexplained merely on the basis of a post-search departmental valuation report. A valuation report obtained after search is only an estimate of construction cost and does not itself constitute incriminating material. Consequently, additions lacking a nexus to seized material are impermissible under Section 153A, and the relevant assessments were quashed.

Alleged unaccounted credits cannot be sustained solely on third-party diary entries and the statement of an entry operator's son where no substantive independent evidence links the deposits or transactions to the assessee. Names entered in a diary on the deceased operator's oral instructions create, at most, a reasonable probability and do not establish that the assessee deposited funds into the operator's bank accounts. In the absence of corroborative evidence, the addition is unsustainable; deletion of the addition was upheld.

Ex parte reassessment additions for unexplained bank credits, capital receipts from sale of immovable property, and commodity transactions remained unchallenged because no return of income, response to statutory notices, or supporting evidence was furnished. Repeated adjournments did not result in production of material before either the first appellate authority or the Tribunal. Without evidence substantiating the challenges to the additions, no relief was available and the additions were confirmed.

Closing-stock valuation cannot be increased solely because a higher approximate value was declared to a bank where audited books, quantitative records, and the consistently applied cost-or-net-realisable-value method show no defect or discrepancy. Bank declarations do not displace book valuation unless the Revenue identifies unrecorded stock or inaccuracies in the books or stock records. The distinguishable precedent concerned stock omitted from the books. The addition for alleged undervaluation of closing stock was therefore deleted.

Long-term capital gains from shares acquired through an IPO, held in demat form and sold through a recognised stock exchange cannot be treated as unexplained cash credit merely on a general penny-stock investigation report. Documentary proof of subscription by account-payee cheque, demat holding, banking trail, exchange-based sale and securities transaction tax supports genuineness unless rebutted by assessee-specific evidence. The gain remained eligible for exemption and the related addition was deleted. Once the share transactions were accepted as genuine, no basis remained to infer commission paid for arranging a bogus entry; the estimated unexplained expenditure addition was also deleted.

Limited remand proceedings cannot revive an unexplained-investment addition already deleted in an earlier appellate round. The Assessing Officer must remain within the defined remand scope, which concerned determination of actual shareholding using relevant information. Interest expenditure linked to dividend and other income from shareholding is deductible under Section 57 without further verification where that nexus has already been conclusively recognised. Interest under Section 234D is not chargeable where no refund was issued on processing of the return. Interest under Section 220 must be recomputed, if applicable, on total income determined after giving effect to appellate directions.

Interest expenditure connected by a real and proximate nexus to income taxable under "Income from other sources" is deductible under section 57 and cannot be capped merely because the income earned in a particular year is lower. Section 57 does not require expenditure to be incurred solely or exclusively for a particular item of income. Separately, departmental appeals with tax effect below the applicable CBDT monetary threshold are not maintainable unless a recognised exception applies; the policy applies to pending appeals and precludes merits adjudication where no exception is established.

Delayed filing of Form No. 10IC for election of the concessional corporate tax regime may be condoned where the lapse was inadvertent, a condonation application is pending before the competent authority, and the Revenue raises no objection. Applying an approach that permitted acceptance of delayed Form No. 10IC, the Tribunal directed condonation of the delay, enabling the assessee to claim the concessional tax-regime benefit under Section 115BAA.

Interest earned by a co-operative society on savings-account deposits with co-operative banks qualifies for deduction under section 80P(2)(d), where those banks are co-operative societies. The expression "investments" is not confined to fixed deposits and includes interest-bearing savings deposits that are maintained to earn interest and are subject to withdrawal conditions. Consistent treatment of the identical issue in an earlier assessment year supports allowing the deduction absent any material basis for departure. The resulting effect is deletion of the disallowance of such interest income.

Electricity tariff increase of 6.83 per cent after four years is presented as necessary in light of inflation and rising costs. Reducing transmission and distribution losses is identified as a means of limiting future tariff increases. Provision of 200 units of free electricity for poor and needy households through solar panels under the Muft Bijli Yojana is treated as distinct from tariff revisions.

Sugar supply is characterised as adequate, and higher prices are attributed principally to speculative buying and advance stockpiling, alongside lower output, seasonal demand and global price pressures rather than an actual shortage. Duty-free raw sugar imports and stockholding limits are intended to augment availability, curb speculative accumulation and stabilise market sentiment. Imports, existing stocks, special crushing and an earlier crushing season are expected to moderate prices and improve festive-period supply. Ethanol diversion is not identified as a cause of the price movement.

Tamil Nadu Value Added Tax audit-report compliance is extended for registered dealers with a principal or additional place of business in specified cyclone-affected or flood-affected districts. Audit reports for the financial year 2022-2023 furnished on or before 31 January 2024 are deemed to have been furnished within the prescribed time limit. The extension is implemented through a further proviso to rule 16-A(1) of the Tamil Nadu Value Added Tax Rules, 2007.

Article 191 permits a State Legislature to declare that specified offices do not disqualify their holders from legislative membership. In the absence of an express or implied constitutional restriction, that power extends to retrospective exemption, altering the legal consequence of holding the designated office without amending election law. Retrospective validation can therefore preserve an election challenged on an alleged office-of-profit disqualification. The characterisation of a Special Government Pleader's engagement may depend on whether it is a distinct, independently subsisting office or a proceeding-specific assignment. A candidate accused of corrupt practices is a necessary respondent only where that candidate contested the constituency covered by the election petition.

Corporate guarantee services supplied between related persons to a banking company or financial institution for the recipient are valued at one per cent of the guarantee amount or actual consideration, whichever is higher. Settlement under rule 142 requires an intimation. Provisional attachment ceases on release or after one year, whichever is earlier. Registration, cancellation, tax collected at source reporting, and GST practitioner enrolment forms are revised, including recognition of One Person Companies and specified qualifications for GST practitioners.

GST on accommodation is charged on the actual amount received, while declared tariff determines the applicable rate slab. Casino entry and gambling are separate taxable supplies, with gambling and horse-racing GST calculated on total bet value. Below-threshold accommodation providers using electronic commerce operators need not register where the operator pays GST. Sale of books is a supply of goods where the supplier owns and may sell them on its own account. Legal services supplied by advocates to business entities are taxable under reverse charge, payable by the recipient.

Attestation by a person with a subsisting interest in property may create estoppel against denying the instrument's title and recitals where surrounding circumstances establish knowledge, consent and acquiescence; mere attestation alone is insufficient. Acting as the owner's power agent and recording the settlement transaction supported knowledge of the settlement. A Will may be validly proved through attesting witnesses and circumstances demonstrating the testatrix's sound disposing state of mind, without a preparatory note or express declaration that it is the last Will. Judgments not inter partes cannot operate as res judicata or conclusively prove title, but may evidence continuing assertion or treatment of property rights.

Wheat export policy has been revised from prohibited to free with immediate effect, lifting the export ban on wheat and related wheat products. The liberalised export treatment extends to wheat flour, maida, semolina and wholemeal atta. The restriction had been imposed to address rising domestic prices, and its removal is expected to improve international wheat availability.