Protective and substantive assessments cannot be imposed on the same receipt in the hands of the same taxpayer; the Revenue must select one assessment method. Under the post-1 January 2020 agreement, remote performance from outside India and the absence of employee visits to India did not support a current-year finding of a permanent establishment, so the receipts could not be taxed as business income under Section 44DA. Treaty characterisation as fees for technical services requires a factual finding that technical knowledge or skills were made available for the recipient's independent future use. That issue requires fresh examination of the agreements, service scope, recipient capability, and UK tax treatment.

Transfer-pricing adjustments for intra-group services and fixed-asset purchases were deleted because closely linked international transactions had been benchmarked under an accepted aggregated Transactional Net Margin Method. Selectively segregating intra-group services and assigning a nil arm's length price under the Comparable Uncontrolled Price Method was unsustainable without reliable comparable uncontrolled transactions; evidence also established receipt of services and tangible benefits. Treaty-based relief for dividend distribution tax may be raised as an additional claim in appellate proceedings without filing a revised return where required to determine correct tax liability. The claim was admitted for fresh adjudication after final resolution of the pending substantive legal issue.

Deduction for political contributions under Section 80GGC is unavailable where the claimed payment forms part of a bogus-donation arrangement. The recipient political party had not filed statutory contribution reports from FY 2013-14 and did not meet conditions associated with exemption under Section 13A. Material concerning the party's sham donation mechanism, applied consistently with a coordinate-bench decision involving donations to the same party in the same year, showed that the contribution was not genuine. Payment through banking channels alone did not establish eligibility for the deduction.

Registration under Section 12AB cannot be refused solely because a trust deed is unregistered. Non-registration, by itself, does not justify rejection; the relevant legal requirements concerning the trust's immovable property and any registration before the Charity Commissioner require reconsideration. The trust must also receive an adequate opportunity to rectify any identified defects before a fresh decision is made. The rejection was set aside and the registration application was restored for fresh adjudication.

Search-related assessments under Section 153C were valid because seized material pertained to the assessee and was connected with alleged bogus sales entries routed through searched entities. Sales through those entities were treated as bogus after search evidence and enquiries established that they provided accommodation entries. However, a reduced commission-rate addition lacked support from segmental comparables and was excessive because the sales were treated as bogus only once. Taxable profit was therefore confined to gross profit estimated at 1% or the gross-profit rate disclosed in the books, whichever was higher.

Exemption under section 10(23C)(vi) should not be denied solely because the audit report in Form 10B was not furnished with the return where it was uploaded and available to the Assessing Officer before processing under section 143(1). Although furnishing Form 10B is mandatory, its timing and mode of filing are procedural. The report should therefore be considered in determining the exemption claim, and the assessment should be rectified accordingly.

Estimated profit additions based solely on alleged suppressed sales cannot stand where the underlying GST appellate findings establish no evidence of clandestine removal, unrecorded sales, interstate movement, unaccounted raw materials, sale proceeds, transportation, or other corroborative material. As no independent evidence supported the income-tax addition beyond the GST information, the estimated addition for alleged undisclosed profit was deleted.

Belated furnishing of Form No. 10 does not by itself bar a charitable trust's exemption claim for accumulated income under Section 11(2) if the prescribed information was available to the Assessing Officer before completion of assessment. Although furnishing the form is mandatory, compliance is sufficient when it is on record before return processing. The exemption claim must nevertheless be reconsidered on its merits, including verification of the factual conditions governing accumulation.

Where recorded sales are accepted and actual procurement is not disproved, an addition for alleged bogus purchases is confined to the profit element embedded in those purchases rather than the entire purchase amount; profit estimation at 12.5% was treated as justified. A difference between Form 26AS contract receipts and recorded turnover does not constitute taxable income in the year of receipt where it represents contractual advances carried as liabilities and recognised as income in the subsequent year, supported by corresponding tax deducted at source treatment. The Revenue's contested additions were therefore not restored.

Delayed furnishing of Form 10B does not disentitle a registered charitable trust from exemption for application of income where the audit report is available to the assessing authority before processing of the return under section 143(1). The requirement is met when the report is furnished before return processing. A rule requiring a declaration to opt out of exemption under section 10B was distinguishable because that declaration directly affects the return and assessment from the outset. The applicable principle is that an audit report submitted before completion of assessment supports an exemption or deduction claim; accordingly, the trust's exemption claim was sustained.

Purchases from an unverified supplier may warrant taxation only of the profit or savings embedded in those purchases where corresponding sales, stock records, quantitative movement and bank payments are accepted. Supplier non-verification, cancelled GST registration and failure to establish procurement from the named supplier support an estimated addition, but prior-year rates do not automatically apply without identical facts. For low-margin ferrous and non-ferrous metals trading, disclosed net-profit margins and comparable decisions supported restricting the addition to 2 per cent of disputed purchases and deleting the balance.

Interim release of cash to the Income Tax Department, secured by an indemnity bond and retention in an auto-renewable fixed deposit with a nationalised bank, preserved the amount pending determination of its source, tax liability and ownership. The arrangement did not finally decide the claimant's rights or create an adverse finding. Questions concerning entitlement to the cash remain open for determination in the pending income-tax proceedings, and interference with the interim arrangement was declined.

Subsequent judicial developments on the evidentiary relevance of the Shah Commission Report require reconsideration of challenges to reassessment notices where that report may have formed the basis for recorded reasons to believe. The challenges to the notices should be heard together with substantive challenges to reassessment orders for the same assessee and assessment years. Whether the recorded reasons relied solely on the Shah Commission Report or also on other material remains open for determination. The prior dismissal of the writ petitions was set aside, and the notice challenges were directed to be reconsidered afresh with all contentions kept open.

Deletion of penalty solely because the underlying assessment orders had been quashed could not stand after the orders quashing those assessments were set aside in connected appeals. The Tribunal had not examined the penalty proceedings on their merits or addressed the other legal issues. The penalty matter therefore required fresh adjudication on the merits and applicable legal issues, and the Tribunal's order deleting the penalty was set aside and remitted for reconsideration.

Reassessment proceedings under Section 148A require consideration of the assessee's replies and material before an order is passed under Section 148A(d). Where the replies were not addressed and no effective opportunity was given to submit further pleadings and documents in response to Section 148A(b) notices, the Section 148A(d) orders and consequential notices cannot stand. The proceedings were set aside and restored to the Section 148A(b) stage for a fresh opportunity and reconsideration in accordance with law.

Statutory notices for scrutiny, information and final show cause sent solely to a former statutory auditor's email addresses did not provide the assessee an effective opportunity to respond. As the assessee neither received the notices nor participated in the resulting assessment, a justice-oriented approach required fresh consideration after a sufficient and reasonable hearing opportunity. The ex parte assessment, consequential demand and penalty proceedings were set aside, with the matter restored to the stage for replying to the scrutiny notice.

Failure to file objections to a draft assessment order before both the Dispute Resolution Panel and the Assessing Officer permits completion of assessment on the draft order under the statutory scheme. Where an appeal against that assessment is available under the tax statute, the alternative remedy is treated as efficacious and writ jurisdiction under Article 226 is not warranted. The stated position is that the writ petition is not entertainable, while the taxpayer may pursue the statutory appeal and raise all merits there.

Refunds determined under Form No. 4 under the Direct Tax Vivad Se Vishwas Scheme, 2024 require an effective processing mechanism and timely credit. The stated absence of a processing module and engagement in time-barring proceedings were noted as inadequate explanations for prolonged non-credit. Although the Scheme excludes statutory interest under the Income-tax Act, that exclusion does not justify administrative delay. Further time was granted, and the matter was listed for a later date; the order was also sent to CBDT for verification and appropriate systemic action on recurring refund delays.

Reopening assessments requires approval or sanction from the competent authority under section 151, including where notice is issued within four years and limitation is considered with the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act. The text records that the Supreme Court declined to entertain the special leave petition and dismissed it, leaving the High Court reasoning on the validity of reopening undisturbed.

Prior-period expenditure is allowable where the liability crystallises during the relevant year. Special leave petitions challenging the application of this principle were dismissed because the issue was no longer open to debate, following earlier decisions concerning the same question. Special leave petitions against penalty imposed for concealment in relation to additions later deleted were also dismissed, as the penalty proceedings were consequential to the underlying additions.