Reassessment notices must be transmitted to the proper person within the limitation period; digital signing alone does not satisfy Section 149. Where postal records show booking after the statutory deadline, dispatch is not compliant with Section 282 read with Rule 127. Section 292BB cannot cure non-service when the assessee objects during assessment proceedings. A notice dispatched after limitation is time-barred, rendering the consequential reassessment invalid.

Online gaming winnings under Section 115BB must be identified after setting off participation buy-in amounts against gross gaming receipts. Although Section 58(4) bars deductions for expenditure incurred in earning such winnings, it does not permit gross receipts to be treated automatically as taxable winnings without determining the net result of the gaming transactions. Where platform data shows that total buy-ins exceed gross winnings, no taxable gaming income arises. The gross-winnings addition was therefore deleted.

Penalty for misreporting of income under Section 270A(8) requires identification of the applicable clause in Section 270A(9) and findings that its statutory ingredients are met. Imposing penalty solely because a capital-gains addition was made, while merely using the term "misreporting" without specifying the relevant clause or supporting particulars, is arbitrary. The penalty was therefore unsustainable and deleted.

An assessment framed under Section 147 read with Section 144C(3) is not a best judgment assessment under Section 144. Consequently, the proviso to Section 251(1)(a) does not permit the appellate authority to set aside that assessment and remit it for fresh assessment. The appellate authority must decide the grounds of appeal on merits through a speaking order, after providing reasonable opportunity to both parties and complying with Rule 46A where applicable. A remand order issued without merit-based adjudication must be set aside, with the appeal restored for adjudication on the grounds raised.

Commission earned by a telecom recharge-voucher distributor, rather than gross bank receipts routed to obtain and supply vouchers, constitutes its business turnover where the distributor acts on commission. Amounts passing through the bank do not represent the distributor's purchases or sales when tax deduction records support commission-based income. As the commission income remained below the prescribed tax-audit threshold, no audit obligation arose and penalty for failure to obtain an audit was unsustainable.

Section 119(2)(b) permits admission of delayed income-tax refund claims where relief is required to avoid genuine hardship, without prescribing a limitation period. The six-year restriction in Circular No. 9/2015 cannot curtail that statutory discretion, although departmental circulars bind income-tax authorities. Refund-condonation applications rejected solely for exceeding that period require fresh consideration on merits, including in constitutional writ proceedings.

Absence of exempt income precludes disallowance of expenditure relating to exempt income. Where appropriate tax has been deducted on payments, deduction under a withholding provision regarded as incorrect does not justify expenditure disallowance when the order treating the taxpayer as in default has been set aside. Expenditure disallowed under the exempt-income provisions is not required to be added back in computing book profit under the relevant minimum alternate tax adjustment. The asserted disallowances concerning exempt-income expenditure, tax withholding classification and book-profit computation are therefore unsustainable.

Reassessment proceedings concerning a deceased assessee must be initiated against the legal representatives where the tax authority had prior notice of the death. Section 159 of the Income-tax Act permits proceedings begun during the assessee's lifetime to continue against legal representatives and permits proceedings capable of being initiated against the deceased to be initiated against them. A reassessment notice issued after death in the deceased's name cannot be sustained. Fresh notice must be issued to the legal representatives, and the specified period is excluded when computing limitation.

Section 153C proceedings require a satisfaction note to be recorded when proceedings against the searched person are initiated, during those proceedings, or immediately after their completion. Recording satisfaction more than four years after completion of the searched person's assessment does not meet the requirement of immediate recording. Pandemic-related disruption and the faceless assessment scheme do not justify that delay. Consequently, the delayed satisfaction note invalidates the proceedings against the person other than the searched person, requiring the notice, consequential assessment order and demand notice to be quashed.

Priority under section 26E of the SARFAESI Act places a secured creditor's registered security interest ahead of government revenues, taxes and cesses. An income-tax attachment predating CERSAI registration can displace that priority only where it was validly enforced and publicly proclaimed as required by law. Failure to establish the required proclamation or registration of the revenue claim or attachment with CERSAI prevents the attachment and resulting encumbrance from prevailing. The secured creditor's dues therefore take priority, and the unproclaimed income-tax attachment is liable to be removed.

Deductions under Sections 80-IA and 80-HHC are governed by the distinction between computing a deduction and allowing it. Deduction under Section 80-HHC must be computed on gross total income before deduction under Section 80-IA is allowed; therefore, the Section 80-IA deduction is not reduced from business profits when calculating the Section 80-HHC deduction. The combined deductions remain subject to the ceiling that they cannot exceed the profits and gains of the eligible business.

Sufficient cause under section 260A(2A) of the Income-tax Act can encompass a short filing delay where record movement, legal advice, administrative approval, appeal preparation and execution collectively show bona fide diligence rather than negligence or inaction. The provision contains no language barring condonation after expiry of the limitation period. Assessment of the proposed appeal's merits remains outside delay-condonation review. On these principles, the 31-day delay in filing the income-tax appeal was condonable.

Challenge to an intimation under section 143(1) was not pursued through the writ route because an alternative statutory remedy was available. The Special Leave Petition was dismissed, while preserving liberty to approach the ITAT under that remedy and to seek condonation of delay. The matter highlights appellate recourse and delay-condonation relief where writ proceedings are affected by inordinate delay and laches.

Condonation of delay in filing a Special Leave Petition requires reasons that are satisfactory and legally sufficient. A 900-day delay relating to an income-tax dispute involving unexplained credits, a Section 153C notice, and search proceedings was not condoned because the stated reasons failed that standard. The Special Leave Petition therefore did not proceed on its substantive issues.

Reopening proceedings raised the issue whether reasons to believe rested on borrowed satisfaction or the assessing authority's independent satisfaction, concerning expense disallowances for purchases treated as bogus. The Supreme Court dismissed the SLP after condoning delay, finding no ground to interfere with the High Court judgment and order. The challenge to the reopening and related disallowances therefore did not proceed further before the Supreme Court.

Rectification of a mistake in apportioning available input tax credit is addressed through the applicable Standard Operating Procedure dated 14 October 2025 and Section 161 of the Telangana GST Act, 2017. The proper officer is required to rectify the ITC apportionment in accordance with that framework. A rectification order remains subject to the appropriate appellate remedy, enabling the affected party to challenge the corrected determination through an appeal.

Section 107(8) requires a personal hearing before a statutory appeal is dismissed as time-barred where a delay-condonation application is pending. Dismissing the appeal without hearing the applicant on the reasons for delay breaches the mandatory hearing requirement and denies an opportunity to explain the delay. Such dismissal is legally unsustainable, requiring the delay-condonation request to be considered after affording a personal hearing.

Rectification under the applicable GST enactments is limited to patent errors apparent from the record. Where supporting documents were not furnished and no apparent error in the original order was established, rectification of an under-declaration of ineligible input tax credit could not be granted. The rejection of the rectification request was therefore valid, leaving the finding of under-declared ineligible input tax credit unchanged.

Revocation of cancelled GST registration may warrant a further opportunity where a show-cause notice remained unanswered for medical reasons and outstanding tax liabilities were not addressed. Rejection of the revocation application was set aside subject to filing a reply and furnishing the undertaking required under Rule 23 to pay outstanding tax, interest and penalty. The competent authority must then determine the revocation application in accordance with law.

Interim protection from arrest in a GST investigation was granted pending interrogation, subject to the petitioner appearing before the Investigating Officer. Relevant considerations included the petitioner's claimed resignation before the alleged transactions, the absence of notice identifying him as an accused, the documentary nature of the material, and willingness to cooperate. The investigating side indicated that arrest could not be made under the notices issued to the petitioner. Further time was allowed for a response before the next hearing.