Customs broker licence revocation and security forfeiture require established substantive misconduct affecting customs revenue or integrity; procedural licensing failures may instead warrant a monetary penalty. Address-change non-intimation, failure to obtain operational permission, and signature-related irregularities were treated as regulatory lapses, while subletting and concealment allegations required concrete proof. Electronic filing and use of intermediaries did not by themselves establish subletting. Due-diligence and client-advice obligations during customs clearance do not extend to exporters' subsequent excess RoSL availment. Accordingly, unproved allegations and procedural breaches did not support licence revocation, and the broker was not responsible for exporters' downstream conduct.

Delay in pronouncement of a reserved indirect-tax writ petition prompted its release for fresh hearing before the regular Bench handling such petitions. Applying the timely-pronouncement principle concerning reserved judgments, the Bench considered that it could not comply with the stipulated timelines and therefore directed reassignment rather than deliver the reserved judgment. Interim status quo was continued for four weeks pending placement before the regular Bench.

TDS credit reflected in Form 26AS cannot be denied merely because it was omitted from the original return and later claimed through rectification of an intimation under Section 143(1). Where the corresponding income has been offered to tax for the relevant assessment year, the Assessing Officer must verify both the TDS claim and inclusion of that income, and allow the credit if verified. Denial of a verified tax credit would cause unjust enrichment and conflict with the principle that tax may be collected only under authority of law.

Corporate-guarantee pricing is benchmarked at 0.5%, while interest on a commercially risky, subordinated loan linked to Siam Commercial Bank is recomputed at 9%. A further ad hoc disallowance of foreign travel expenditure is unwarranted where 20% has already been disallowed and subjected to fringe benefit tax. For captive-power transfers, the electricity market value for the Section 80IA deduction is the State Electricity Board tariff charged to industrial consumers, rather than a cost-plus rate. Carbon-credit sale proceeds are capital receipts; the prospective tax provision applicable from assessment year 2018-19 does not govern earlier years.

Contemporaneous evidence on intra-group support-service payments, including service rendition, benefits, costs and arm's-length character, may be admitted where limited response time and non-production provide sufficient cause. Its verification requires fresh transfer-pricing determination with opportunity to both sides. Reserve for Unexpired Risks cannot be added to book profit under clause (b) of Explanation 1 to section 115JB where it was not debited to the statement of profit and loss. The book-profit computation must therefore exclude such a reserve, consistently with the settled position.

Licence-fee valuation for a limited right to use patents was resolved through a lump-sum estimate because independent expert reports applying the cost approach produced materially different results, while the departmental valuation relied on objections lacking comparable domain expertise. The appellate estimation power was used only in these exceptional factual circumstances and was expressly treated as non-precedential. The licence fee attributable to the limited-use patent right was estimated at USD 900,000, requiring consequential computation of taxable royalty income.

Unverified purchases cannot be disallowed in full where corresponding sales are accepted and the procurement of goods from the market is established, albeit without proper supplier billing. The taxable addition should be confined to the profit element embedded in such purchases rather than the entire purchase value. Considering the nature of the business and surrounding circumstances, estimation at 12.5% was treated as excessive and reduced to 6.5% of the unverified purchases, with the resulting addition sustained accordingly.

Section 270A distinguishes under-reporting from misreporting and requires a penalty notice to identify the precise misreporting charge, including the relevant statutory limb, to enable an effective response. An undifferentiated notice and initiation lacking that specification violate natural justice and cannot support a misreporting penalty. Disclosure and taxation of additional professional income after search, without further material, do not by themselves establish misreporting. Section 271AAD targets false entries or omissions in books used to evade tax, particularly fraudulent documentation; unaccounted cash offered as professional income does not fall within that mischief. Penalties also require a valid jurisdictional assessment foundation.

Retrospective application of section 292BC prevents invalidation of search assessments merely because approval under section 153D is alleged to lack sufficient reasons or contain defects in form or authentication. The common approval consequently does not invalidate the assessments. For alleged accommodation-entry loan transactions, commission income requires a supportable estimation based on relevant market comparables; differing rates and an unexplained uniform rate cannot be accepted in full. On the stated peculiar facts, taxable commission is confined to a uniform 0.15% rate, without precedential effect.

Actuarially determined provisions for accumulated non-encashable sick leave may constitute accrued, reasonably ascertainable business liabilities deductible under Section 37(1). Employees earn the right to carry forward and use paid sick leave through services rendered during the relevant year; future use requires paid absence without corresponding services, creating an economic obligation. Uncertainty over the employees who will use leave or the timing of use does not make the liability contingent where actuarial valuation provides a scientific estimate. Section 43B(f) does not apply where no sum is payable for leave encashment. Consistent accounting treatment of an identical recurring item should not ordinarily change without material changes in facts or law.

Club membership, subscription and service expenditure is deductible when incurred wholly and exclusively for business; an ad hoc disallowance requires identification of personal or non-business payments. Where own funds exceed investments and borrowings are demonstrably used for business purposes, investments are presumed to be made from own funds, precluding interest disallowance for exempt-income investments. Administrative expenditure attributable to exempt income cannot exceed that income. Depreciation and additional depreciation are available where contemporaneous internal records establish that machinery was installed and put to use before year-end; an external installation certificate is not indispensable. Electrical installations integral to manufacturing machinery qualify for additional depreciation based on functional use, absent proof of independent non-manufacturing use or statutory exclusion.

Interest on borrowings used to acquire assets held as stock-in-trade or current assets for resale is deductible as business expenditure under Section 36(1)(iii). The proviso deferring deduction until an asset is put to use does not apply where assets are acquired for resale rather than for the taxpayer's own business operations. Acquisition-related expenditure is likewise deductible under Section 37(1) where it relates to stock-in-trade, not capital assets acquired for operational use. The treatment depends on the assets' business purpose and character as trading assets, making both interest and related acquisition expenditure revenue deductions.

Cash sale consideration accepted in contravention of Section 269SS may not attract penalty under Section 271D where reasonable cause is established. Relevant circumstances include fragmented family ownership, agricultural background, urgency to sell, purchaser insistence on cash, bona fide ignorance of the restriction, and full disclosure of consideration for tax purposes. Consistent treatment of co-owners involved in the same land-sale transaction also supports parity. These factors support deletion of the penalty where they collectively demonstrate reasonable cause.

Prior approval under section 151 must be obtained before issuing a notice under section 148; approval obtained afterwards invalidates the assumption of reassessment jurisdiction. Reassessment also cannot sustain independent additions where no addition survives on either of the recorded reasons for reopening. Interest on delayed payment of indirect taxes, including excise duty and service tax, is compensatory and allowable as a business deduction because section 40(a)(ii) applies to direct taxes. Where interest-free own funds substantially exceed interest-free advances, the advances are presumed to be funded from own funds and no interest disallowance arises under section 36(1)(iii).

Reassessment notice under Section 148 issued after expiry of the pre-amendment limitation period is barred where the amended reassessment regime does not revive a time-barred matter. The first proviso to Section 149(1) prevents issuance of a notice that could not have been issued under the earlier limitation provisions. Where the notice concerns the same underlying issue already raised in Section 153C proceedings, reassessment jurisdiction is also unavailable. The Section 148 notice was therefore time-barred and without jurisdiction.

Quasi-judicial assessment requires the Assessing Officer to independently evaluate evidence and determine taxable income; administrative supervision cannot displace statutory discretion or dictate the assessment. An addition for undisclosed consideration on plot sales requires reliable corroborative evidence. WhatsApp communications, images, or third-party statements alone cannot establish on-money where they do not concern the recorded transactions, purchasers deny cash payments, and valuation or comparable-sale evidence supports registered consideration. Search-related presumptions are rebuttable and cannot support extrapolated additions without a cash trail, purchaser admission, corroboration, and an effective opportunity to cross-examine adverse witnesses.

Digital signing is mandatory for assessment orders issued through e-assessment proceedings. A mere reference to the date of a digital signature does not satisfy that requirement where no digital signature is actually affixed. An unsigned assessment order is incomplete, non est and invalid because the absence of signature constitutes a jurisdictional defect rather than a curable procedural irregularity. Such an invalid order cannot be remanded for fresh assessment and must be quashed.

Section 68 requires an assessee to establish creditor identity, transaction genuineness and prima facie creditworthiness. Confirmations, PAN details, bank records, income-tax particulars, loan accounts and banking-channel repayments discharge the initial burden, after which the Revenue must produce cogent rebuttal evidence through meaningful inquiry. Low declared income, preceding cash deposits or incomplete documentation may warrant investigation but do not alone prove that loan credits are undisclosed income. The unsecured-loan addition was therefore deleted. Employees' PF/ESI contributions remain deductible only if deposited within the due date under the applicable welfare law; payment before the income-tax return-filing due date does not cure delay. The related disallowance remained payable.

Cash-expenditure disallowance requires evidence of an actual prohibited cash payment to an identifiable person; a presumption that purchases from an alleged accommodation-entry provider were made in cash is insufficient. Where purchase and sales records, quantitative details, stock particulars and corresponding export sales are accepted, and the books are not rejected, purchases cannot be disallowed merely because the recorded supplier's identity is disputed. An unpaid supplier balance reflecting accepted purchase transactions is a trade credit, not unexplained cash credit, where no money was received during the year. Taxing both purchases and the corresponding trade payable would create a double addition.

Section 144C requires a draft assessment order before a final assessment is made against an eligible non-resident assessee where the proposed variation is prejudicial. Direct issuance of a final assessment order without the mandatory draft-order procedure renders the final order void. The omission is not a curable procedural irregularity, so the assessee is entitled to have the invalid final assessment set aside.