Recognised stock exchanges fall within the definition of public authority under Section 2(h) of the Right to Information Act, 2005 where governmental control is deep and pervasive. Ownership, control and substantial financing in the inclusive limb operate disjunctively. Statutory recognition under the Securities Contracts (Regulation) Act, 1956 is constitutive rather than merely regulatory because an entity cannot operate as a stock exchange without it. SEBI's recognition order, exercised through delegated Central Government power, is attributable to the Central Government. The National Stock Exchange is therefore amenable to the RTI Act under both the first and inclusive limbs of Section 2(h).

Section 5 of the Limitation Act, 1963 applies to appeals under Section 9 of the Chhattisgarh Rajya Suraksha Adhiniyam, 1990. Under Section 29(2), provisions on limitation, including condonation of delay, apply to special or local laws prescribing distinct limitation periods unless expressly or necessarily excluded. The thirty-day appeal period contains no bar on extension, no outer limit for condonation, and no self-contained limitation scheme. Exclusion of time for obtaining a certified copy further indicates that general limitation principles are not wholly displaced. Delay may therefore be condoned upon sufficient cause, preserving the appellate remedy against externment orders.

Complete settlement of operational debt before pronouncement of a Section 9 admission order, coupled with a pending withdrawal application by the operational creditor, prevents the insolvency proceedings from validly resulting in admission to CIRP. The withdrawal request should be processed where payment and settlement occurred before admission. CIRP initiated despite the pre-admission settlement and pending withdrawal application is unsustainable and should be withdrawn.

Seized goods must be returned under Section 110(2) of the Customs Act, 1962, if notice under Section 124(a) is not issued within six months of seizure. The period may be extended only once, for up to a further six months, by the competent authority for recorded reasons and after prior intimation to the person concerned. Expiry of the statutory period without notice renders continued detention of seized gold jewellery impermissible; a hearing notice issued after proceedings begin cannot cure the lapse. Release may be directed subject to payment of applicable customs duty and warehousing charges.

Interest on NRE/FCNR deposits retained by a returning non-resident until maturity remains exempt where retention is permitted under the foreign-exchange regime; the exemption is not confined to continuing non-residents. Presumptive interest on foreign investments cannot be taxed without evidence of actual receipt or accrual, and disputed foreign-currency bank credits require bank verification before being treated as unexplained income. Chapter VI-A deductions, along with consequential deduction and rebate claims, were allowable in the stated circumstances. Reassessment reopening based on information concerning foreign bank accounts remained valid, while the related income additions required correction or fresh factual determination.

Penalty for under-reporting is not automatic: a valid show-cause notice, reasonable opportunity, and identification of the applicable statutory clause are required before levy. Where no notice followed initiation in assessment orders and no penalty was imposed, appellate confirmation of initiation was premature. Intimation adjustments do not merge automatically into a later scrutiny assessment; they may be challenged in an appeal against that assessment only if the assessment considered and decided them. Otherwise, a separate statutory appeal against the intimation is required. Liability for delayed-return interest requires factual verification where timely filing of the original return is claimed.

Section 69A requires material establishing that money or specified valuable assets found in an assessee's possession are unexplained. Cash traced to prior bank withdrawals and supported by cash-book records cannot be treated as unexplained without evidence that it was used elsewhere or derived from an undisclosed source. An alleged excess sale consideration cannot rest solely on a self-incriminating statement without independent verification or corroborative evidence of receipt. Differences in sundry creditor balances, particularly where draft accounts are subsequently reconciled in audited financial statements, do not constitute unexplained money under Section 69A because creditor discrepancies fall outside the provision's specified subject matter.

Interest awarded under section 28 of the Land Acquisition Act on enhanced compensation for compulsory acquisition of agricultural land is treated as an accretion to the land's value and forms part of enhanced compensation. It differs from interest under section 34, which compensates for delayed payment. Provisions governing taxation and timing of interest on compensation receipts do not alter the capital character of section 28 interest. Consequently, section 28 interest qualifying as enhanced compensation is eligible for exemption available for compulsory acquisition of agricultural land and is not taxable as income from other sources.

Consolidated determinations of tax-deduction default and interest liabilities across multiple assessment years, instead of separate quarterly orders for each relevant year, are identified as procedurally invalid. Combining assessment years 2010-11 to 2015-16 into one order under Sections 201(1) and 201(1A) is treated as a defect invalidating the assessment proceedings from inception. The resulting consolidated order is regarded as void ab initio and liable to be quashed.

Employees' ESI/PF contribution - statutory due date for deduction - Verification of actual salary payment date for ESI/PF due-date computation Employees' ESI/PF contribution-statutory due date for deduction - Disallowance of employees' ESI/PF contributions deposited after the due date prescribed under the respective welfare statutes - HELD THAT: - The relevant due date for deduction of employees' contributions is the due date under the corresponding ESI/PF statute and not the ... ... ...

Unexplained cash deposits - Cash component of property sale consideration HELD THAT: - The execution of a sale deed in the relevant financial year supported the inference that the cash deposits, though not wholly reconciled, in light of MALINI RAMNATH RELE (MRS.) [1993 (9) TMI 319 - ITAT MUMBAI] represented the cash component arising from that sale. In the peculiar facts, the addition was restricted on a lump-sum basis and was expressly held not to constitute a precedent. [Paras 4] The add... ... ...

Search-related reassessment of person other than searched person - Primacy of assessment u/s 153C over reassessment u/s 148 Validity of reassessment notices issued u/s 148 to the assessee on the basis of incriminating material seized during a search of another person - HELD THAT: - The material forming the basis of reassessment was seized in the search of another group and related to the assessee. Following Shyam Sunder Khandelwal [2024 (4) TMI 196 - RAJASTHAN HIGH COURT] the Tribunal held... ... ...

Rejection of the application for approval u/s 80G(5) - trust objects permitted application of funds outside India - HELD THAT: - The assessee stated that it had neither applied funds outside India nor intended to do so, and that it had initiated amendment of its Trust Deed to restrict its operations to India. The Tribunal considered it appropriate that the amended objects or Trust Deed be placed before the competent authority for consideration in accordance with law. [Paras 5] The rejection ... ... ...

Accrual of liability for statutory audit fees - disallowance of belated employees' EPF contributions Accrual of liability for statutory audit fees - Contingent liability - Allowability of provision for statutory audit fees where audit services had not been rendered during the relevant year - HELD THAT: - Although audit fees constitute allowable expenditure, liability does not accrue until the audit is conducted. A provision made before rendering of audit services remains contingent and ca... ... ...

Reassessment beyond four years - failure to disclose fully and truly material facts - Change of opinion Validity of reassessment initiated after four years from the end of AY.2006-07 in respect of depreciation and additional depreciation on the new building and plant and machinery - HELD THAT: - The original assessment under section 143(3) had been completed after the Assessing Officer raised and considered queries concerning the MIDC completion certificate and statements of the assessee'... ... ...

Revisionary jurisdiction over issues outside limited scrutiny - Share application money genuineness and excess share premium valuation Validity of revision on the alleged excess share premium where the limited scrutiny was confined to genuineness of share application money and its disclosed source - HELD THAT: - The enquiry into whether share application money was genuine and from disclosed sources concerned its identity and source, whereas the proposed taxation of share premium under section... ... ...

Restriction on reassessment notice under first proviso to section 149 - Limitation for reassessment notice for Assessment Year 2015-16 Validity of the reassessment notice issued for AY 2015-16 after expiry of the erstwhile six-year limitation - HELD THAT: - As evident from the law laid down in HEXAWARE TECHNOLOGIES LIMITED [2024 (5) TMI 302 - BOMBAY HIGH COURT] for assessment years preceding the amended regime, the first proviso to section 149 preserves the restriction arising under the erstw... ... ...

Deduction for interest income from investments with co-operative banks - Deduction claimed by a co-operative housing society for interest earned on deposits with co-operative banks HELD THAT: - The assessee's case was found not to be distinguishable from the coordinate Tribunal decision in PATHARE PRABHU CO-OPERATIVE HOUSING SOCIETY LTD. [2023 (7) TMI 1272 - ITAT MUMBAI] allowing deduction for interest derived by a co-operative society from investments with co-operative banks. The exclusi... ... ...

Unexplained cash deposit during demonetisation - Cash-flow explanation of cash deposits Addition for cash deposited during the demonetisation period, claimed to be sourced from accumulated cash savings and rental income - HELD THAT: - The opening cash claimed in the cash-flow statement was unsupported, since no books of account were maintained. However, the rental income disclosed in the returns supported the existence of a regular cash source after the stated opening date. As the cash-flow s... ... ...

Exemption for investment in new residential house u/s 54F - Additional evidence before Appellate Tribunal - Admission of the purchase agreement and bank statements as additional evidence to substantiate the claimed exemption for investment in a new residential house - HELD THAT: - The additional documents were material to determination of the exemption claim, and the explanation for their non-production earlier was accepted. As the revenue authorities had not placed any material contrary to the ... ... ...