Writ jurisdiction under Article 226 does not extend to resolving disputed factual questions concerning an authorised representative's presence during customs sampling. The sampling report recorded the representative's presence, while the importer disputed his authority; subsequent sampling admittedly occurred in his presence. Laboratory testing found that the declared industrial oil failed prescribed parameters, and comparable testing standards had previously supported customs action. The seizure challenge was therefore not maintainable on the disputed sampling contention, and the customs action remained sustained.

Customs Broker licensing rules require authorisation from each represented client and reliable verification of the client's identity and functioning before customs transactions are undertaken. Filing a Shipping Bill without the named exporter's authorisation or contact may breach these independent obligations even without proof that the broker knew of prohibited goods. A licence and dongle must not be lent to another person for consideration: permitting use of broker credentials for customs transactions constitutes an impermissible transfer in substance, without requiring transfer of title. Deliberate credential sharing, unauthorised filings and attempted export of prohibited goods may justify revocation, security forfeiture and penalty as proportionate disciplinary measures.

Judicial review of a Settlement Commission order under Article 226 is limited to jurisdictional or statutory error, prejudice, fraud, bias or malice, and does not permit appellate reassessment of settled proceedings. A party that voluntarily elects settlement after not pursuing the statutory appeal cannot indirectly reopen the underlying show-cause notice, including limitation objections, without establishing a recognised ground for such limited review. Settlement of duty liability does not eliminate statutory interest: the Commission may direct the jurisdictional Commissioner to verify and quantify interest, and a higher amount than the party's calculation does not by itself establish illegality or lack of jurisdiction.

Section 54F eligibility depends on whether the taxpayer owns more than one residential house, other than the new residential asset, on the relevant date. Assessment of rental income from a let-out tannery under the head "Income from house property" does not convert that commercial building into a residential house. Ownership of one self-occupied residence and a separately let-out tannery therefore does not, on that basis, disqualify the taxpayer from deduction for investment in a new residential property. Denial of the Section 54F deduction solely because the tannery income was taxed as house-property income is unsustainable.

Reassessment proceedings under Section 148 required prior approval under Section 151 from the competent Chief Commissioner of Income Tax. Approval granted instead by the Principal Commissioner of Income Tax was not valid under the applicable CBDT instructions and the coordinate-bench position. The defect rendered the reassessment notice and all consequential assessment proceedings invalid, resulting in the issue being resolved in favour of the assessee.

Enhanced tax rates for unexplained income amendments without express retrospective effect apply prospectively from Financial Year 2017-18, corresponding to Assessment Year 2018-19 onwards. Where divergent High Court interpretations exist and no binding jurisdictional or Supreme Court authority applies, the interpretation favourable to the assessee prevails; tax for Assessment Year 2017-18 is computed under the unamended provision. Cash deposits lacking documented sources may attract an unexplained-money addition, but the whole deposit need not be treated as unexplained where reasonable cash-in-hand for ordinary requirements is accepted.

Corpus donations received with a specific direction to form part of a charitable trust's corpus are excluded from income under the statutory scheme for charitable trusts. While voluntary contributions generally constitute income for exemption purposes, specifically directed corpus contributions are capital receipts exempt from tax. Such donations should not be included when calculating income to determine whether the audit threshold requiring furnishing of Form No. 10B is met. Where excluding corpus donations leaves income below that threshold, no audit report is required and exemption remains available for the corpus contributions.

Penalty for under-reporting cannot rest solely on confirmation of a disallowance where lease-rental payments were made without tax deduction under a bona fide, disclosed and debatable interpretation that GNOIDA was a Government body exempt from the deduction requirement. The applicability of tax deduction at source depended on GNOIDA's status and raised an interpretational issue. Statutory protection remains available unless the explanation lacks bona fides or relevant material facts were not disclosed. Accordingly, the lease-rental disallowance did not constitute under-reporting of income, and penalty under Section 270A was unsustainable.

Educational wings operated by the same society cannot be treated as separate institutions for the monetary threshold under section 10(23C)(iiiad) merely because they have different names or provide different levels of education. Where operations share a common campus, management, ownership and infrastructure, and lack separate books of account and independent administration, they constitute one composite educational establishment. Their annual receipts must therefore be aggregated. Fragmenting receipts without proof of independent existence would undermine the threshold intended for genuinely small educational institutions, resulting in denial of the exemption where aggregated receipts exceed the prescribed limit.

Deduction for interest earned by a co-operative housing society on deposits with co-operative banks falls within section 80P(2)(d) where the society is a co-operative society and the investment is made with another co-operative society. Co-operative banks registered under applicable co-operative societies law meet the recipient condition. Section 80P(4) restricts a co-operative bank's own eligibility for section 80P deduction, but does not bar another co-operative society from claiming deduction on interest received from such a bank. Where non-jurisdictional High Court views differ, the interpretation favourable to the assessee applies to this beneficial deduction provision.

Approval under section 10(23C)(vi) is available where an institution exists solely for educational purposes and not for profit. Incidental surplus from educational activities does not demonstrate a profit motive when retained and applied to educational infrastructure and facilities. Construction on trustees' land does not itself establish diversion of funds unless material shows siphoning, private appropriation, or pecuniary benefit, particularly where the infrastructure serves educational activities. The State-law registration objection ceased after registration was obtained from the competent Devsthan authority. As no non-educational activity, surplus distribution, income diversion, or private benefit was established, approval was required to be granted.

Excess tax deducted at source is refundable where a return filed in response to a notice under section 148 is accepted in reassessment and nil taxable income is determined. Section 237 creates a substantive refund entitlement when tax paid exceeds the tax properly chargeable, and no statutory bar denies that entitlement solely because the return was furnished under section 148 rather than section 139. The refund is consequential to the reassessment, not an independent claim beyond its scope. Retaining TDS after no tax liability remains would also conflict with Article 265 of the Constitution. Statutory interest applies consequentially.

A reassessment notice under section 148 is issued when digitally authenticated and communicated, not merely when it bears an earlier date. Where the electronic record showed that a notice dated 31.03.2021 was digitally issued by email on 01.04.2021, it fell outside the applicable limitation period. Applying jurisdictional High Court authority on materially identical facts, the notice was time-barred and invalid, resulting in quashing of the reassessment proceedings.

Ex-gratia retrenchment compensation received by BSNL employees under the Voluntary Retirement Scheme, 2019 qualifies for exemption under Section 10(10B) of the Income-tax Act, 1961. Entitlement to the exemption is not defeated merely because the employee offered the amount to tax based on Form 16, omitted the claim in the original return, or had a rectification claim rejected. Appellate powers may be exercised to allow a legally valid exemption claim not made before the Assessing Officer.

Foreign Tax Credit should not be denied solely because Form No. 67 was furnished after the return-filing due date under Rule 128(9). Although the rule required timely filing for the relevant assessment year, it did not prescribe denial of credit as the consequence of delay. The later extension of the filing period and treatment of the requirement as directory support allowing substantive credit where foreign income was offered to tax in India and Form No. 67 with foreign-tax supporting documents was available before processing. The Foreign Tax Credit claim must therefore be examined on merits after accepting the form and related documents, while providing a reasonable hearing opportunity.

Commission expenditure supported by PAN, GST, TDS, tax-return and banking records cannot be treated as non-genuine solely because the recipient does not respond to a departmental notice, absent evidence that the recipient is fictitious, documents are false, or funds returned to the payer. Loan credits are not unexplained where lender identity, prima facie creditworthiness and transaction genuineness are established through tax, confirmation and bank records, unless rebutted by cogent evidence. Small lorry-driver and cleaner payments may qualify as business expenditure where commercially incidental to operations and individual vouchers are impracticable; disallowance requires evidence of bogus, inflated, personal or non-business payments.

Assessment issued and completed in the name of an amalgamating bank after its merger is jurisdictionally invalid where the Assessing Officer knew that the bank had ceased to exist. Such invalidity is not a procedural defect curable under Section 292B, and the successor entity's participation cannot validate proceedings against a non-existent entity. The assessment is therefore void from inception and liable to be quashed.

Section 56(2)(x) applies only where an assessee receives land, a building, or an independently identifiable immovable-property right during the relevant year. A supplementary agreement modifying building plans under a pre-existing property arrangement does not trigger the provision where it neither transfers fresh immovable property nor creates an additional independent proprietary right. Absence of additional consideration supported the conclusion that no qualifying receipt occurred. Stamp duty valuation is relevant only after receipt of qualifying immovable property is established and cannot independently bring the transaction within section 56(2)(x). Accordingly, the addition based solely on the supplementary agreement's stamp duty valuation was deleted.

Section 68 requires identification of a specific unexplained credit; reconciled capital movements and cash deposits recorded in audited accounts from disclosed professional receipts cannot be treated as unexplained without identified defects or cash deficits. Property received on partition of a Hindu undivided family takes the previous owner's cost and holding period, allowing indexed cost computation. Resulting eligible long-term capital loss may be set off against qualifying long-term capital gains and carried forward subject to statutory restrictions. Registered sale consideration received through banking channels, supported by the conveyance and tax-deduction trail and accepted for capital-gains computation, should not also be assessed as an unexplained credit absent evidence of a sham or recycled funds.

Sponsorship receipts from a women's marathon integrally connected with charitable objects of health, fitness, awareness and empowerment do not constitute trade, commerce or business merely because sponsors obtain promotional benefits or the event generates substantial receipts or surplus. Commerciality depends on the activity's intrinsic nature, purpose and manner, not the sponsors' accounting treatment or receipt quantum. The proviso to section 2(15) and section 13(8) therefore do not apply where no independent commercial undertaking or distinct commercial services exist. Furnishing Form 10BB instead of Form 10B is a curable procedural defect where accounts were audited before filing, valid registration existed, and Form 10B was submitted during assessment; it does not defeat exemption under section 11.