Section 112(3) confines the prescribed limitation period to filing an appeal before the Tribunal and does not impose a separate six-month deadline on the Commissioner to review the first appellate order. A departmental appeal filed within the applicable extended filing period therefore remains maintainable even where the Commissioner's review occurred after six months. The maintainability objection was rejected, and the appeal was admitted for adjudication on merits.

Urgent listing of an appeal against GST registration cancellation may be granted without awaiting ordinary Registry scrutiny where sufficient cause and continuing prejudice are shown. Procedural rules permit exemption from procedural requirements and directions necessary for substantial justice, reflecting the principle that procedure should facilitate adjudication rather than defeat substantive rights through technicality. Cancellation preventing the appellant from conducting its sole business justified limited urgent listing, as delay could make appellate relief ineffective. The exemption applies only to listing and does not waive statutory requirements or determine maintainability or merits, which remain open.

Papad Khar, an alkaline manufactured mixture containing sodium chloride, sodium carbonate and sodium bicarbonate, is classified as an inorganic carbonate under tariff item 28362090. It is not covered by Heading 2501 because it is neither crude nor merely physically processed salt, and it does not possess the characteristics of yeast or prepared baking powder under Heading 2102. As a Chapter 28 inorganic chemical outside the relevant exclusions and alternative schedules, it attracts GST at 18%. Exemption for exempt papad does not extend automatically to Papad Khar used as an input; each input and finished product requires separate classification and rate determination.

E-invoicing applies to coaching-service supplies genuinely made to registered recipients where the supplier falls within the notified class and no exclusion applies. Recipient status depends on an enforceable contractual liability to pay consideration; the student may be the beneficiary, while a parent, guardian or sponsoring enterprise may be the recipient only if contractual terms establish that liability. Mere fee payment or provision of a GSTIN is insufficient. Proposed-supply questions may be raised, but recipient identity and place of supply cannot be determined through advance ruling where they require transaction-specific assessment. Supplier e-invoicing obligations operate independently of the recipient's input tax credit eligibility or business purpose.

Reassessment cannot revisit capital-gains and share-sale exemption issues already examined and accepted in a scrutiny assessment on the same facts, as doing so amounts to a change of opinion. Detailed inquiries into share valuation, purchaser identity and creditworthiness, transaction genuineness, and the consequential exemption claim establish formation of an opinion even where the assessment order does not address every query. The change-of-opinion principle applies under the revised reassessment procedure, in which a show-cause notice under section 148A(b) performs the function of recorded reopening reasons. The reassessment notices and related proceedings were quashed; the limitation challenge remained open.

Reassessment based on information linked to GST adjudication requires independent application of the Income-tax Act. Information suggesting escaped income may include material obtained through a CBDT risk-management strategy, but the record must establish that the relevant strategy covers the GST adjudication order. Income-tax authorities cannot rely solely on the GST proceeding or its appellate outcome when issuing or pursuing reassessment. The reassessment notice remained undisturbed, while any reassessment was required to proceed independently under the Income-tax Act and remain open to subsequent challenge.

Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted.

Section 87A rebate is available against tax on total income, including short-term capital gains taxable at special rates under section 111A, for an individual governed by section 115BAC(1A) whose total income does not exceed the prescribed threshold. The rebate applies to the tax liability computed on total income without distinguishing between income taxed at normal rates and income subject to the special rate for short-term capital gains. The stated position sustains entitlement to rebate on tax attributable to such gains.

Reassessment initiated on departmental information flagged through the Insight Portal remains valid where the Assessing Officer independently confronts the taxpayer with the information, considers the response, passes an order under section 148A(d), and then issues notice under section 148. Such information may provide a starting point for enquiry without constituting borrowed satisfaction. However, sale proceeds from shares cannot be treated as unexplained accommodation entries merely on investigation allegations or suspicion where broker transactions, demat records, contract notes and banking channels remain undisputed, and no independent corroboration, cash trail, or link to an entry provider is established. The reassessment survived, but the share-sale addition was deleted.

Uncorroborated electronic records cannot alone support additions for unexplained investments, expenditure, interest, sales or debtor balances unless independent evidence establishes their nexus with the assessee and the recorded transactions. Excel worksheets, payment sheets and electronic debtor data containing inconsistencies, without supplier or debtor verification, books, invoices, banking records or other supporting material, failed this standard; the related additions were deleted. WeChat diary figures were accepted only to the extent actually recorded, with gross profit estimated thereon, because no evidence justified applying a multiplier. Cash-rent expenditure was disallowed for want of receipts, ledger entries, landlord confirmation or payment proof, and unexplained stock investment was sustained because the stock difference remained unreconciled.

Cash deposits fully disclosed through a revised computation during assessment, with tax paid and the computation accepted, may constitute under-reporting rather than misreporting where the assessment does not identify any statutory ingredient of misreporting. Assessment of the deposits as income from other sources does not itself establish misreporting. On that classification, immunity from penalty for under-reporting is available, and penalty imposed for misreporting is unjustified. The appeal was allowed.

Section 54F eligibility depends on residential houses owned by the assessee personally. A residential property owned by a company remains the company's asset and is not treated as owned by its director. Where the assessee also jointly owns a property with a spouse, counting that property still leaves only one residential house other than the property in which the qualifying investment is made. The disqualifying condition for ownership of more than one such house therefore does not apply, and the section 54F deduction remains available.

Revaluation surplus credited to a retiring partner following revaluation of partnership land does not constitute the partner's share in the firm's total income and is not exempt under section 10(2A). For the relevant assessment year, distribution of the enhanced value of partnership assets attracted section 45(4), under which the resulting capital gains were taxable in the firm's hands rather than in the retiring partner's hands. The post-1 April 2021 substituted provisions did not apply. Accordingly, the addition of the revaluation surplus in the retiring partner's assessment was deleted, although the exemption claim was rejected.

Undisclosed business receipts following rejection of books require profit estimation at a fair rate based on disclosed margins, past results and comparable data; the estimated rate was reduced to 12%. Impounded-document presumptions are rebuttable, and entries cannot be selectively used while corresponding outgoings are ignored; unsupported additions were deleted. Standard off-the-shelf software acquired for internal use without copyright transfer is a goods purchase, so no tax deduction at source applies. Stock statements given to banks, uncorroborated loose-sheet notings and estimated election-expense papers cannot alone establish unexplained investment or expenditure. Rejected books cannot support a separate cash-credit addition after bu.....

Section 153C distinguishes a searched person from an other person by the name in the search warrant and the statutory satisfaction recorded; ownership or occupation of searched premises alone does not confer searched-person status. For completed or unabated assessment years, additions must rest on incriminating material found during search that pertains to each relevant year. Material relating to a later year and uncorroborated general admissions cannot support additions for earlier years. In liquor-business profit estimation, commercially plausible indirect expenses cannot be rejected outright solely because complete vouchers are unavailable, and separate addition of expenses already excluded in computing net profit results in impermissible double addition.

Rule 17A(2) distinguishes institutions created or established under a written instrument from those created otherwise than under an instrument. For the latter, absence of a formal trust deed or memorandum of association cannot alone justify rejecting renewal of charitable registration. The registration authority must assess alternative documentary material, including public-trust registration, the underlying application, prior income-tax registrations and other evidence, to establish the institution's creation and continuing existence. Where no adverse finding concerns charitable or religious objects or the genuineness of activities, rejecting renewal solely for want of a separate formal instrument is unjustified. Registration renewal under section 12AB should be granted in accordance with law.

Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.

Section 41(1) applies only where expenditure or a trading liability was previously allowed as a deduction and the taxpayer subsequently obtains a benefit through remission or cessation. Unpaid interest earlier disallowed under section 43B did not satisfy that condition. Continued balance-sheet recognition, with no write-back, waiver, settlement or discharge, also did not establish cessation; a lender's discounted assignment to an asset reconstruction company did not extinguish the debt. The addition was deleted. Depreciation remained available for a mortgaged building in an existing asset block because mortgage does not transfer ownership and no sale, discard, business unavailability or permanent closure was shown; depreciation was allowed.

Interest and dividend earned by a co-operative society from deposits or investments with a co-operative bank qualify for deduction under section 80P(2)(d). A co-operative bank registered under co-operative societies law retains its character as a co-operative society for this purpose. Section 80P(4) excludes a co-operative bank from claiming deduction on its own income, but does not bar another co-operative society from claiming deduction on income derived from investments with that bank. The deduction applies to interest and dividends from the co-operative bank; expense-allocation grounds were not pressed.

Subsisting registration under section 12AB remains legally effective until lawfully withdrawn or cancelled, even if the trust selected an incorrect sub-clause in an earlier registration application. Renewal falls under section 12A(1)(ac)(ii) where an existing section 12AB registration is due to expire. Absence of registration under the earlier section 12A/12AA regime does not justify rejection where no adverse finding concerns the objects, genuineness of activities, or registration conditions. Renewal rejection on that basis was set aside and registration was directed for the applicable period.