Property-investment additions were unsustainable where bank records, donor evidence, the spouse's verified financial capacity, and fixed-deposit encashment records explained the purchase consideration, while disclosed business income reasonably explained registration expenses. The delay in filing the first appeal was supported by sufficient cause in light of the taxpayer's circumstances and lack of professional guidance. A disputed stamp-duty valuation could not be treated as fair market value while a Departmental Valuation Officer reference remained unresolved and the explanation for lower consideration had not been addressed. The appellate delay was condoned, and additions for unexplained investment and stamp-duty value difference were deleted; the assessment-validity challenge remained open.

Article 8 of the India-United Kingdom tax treaty exempts profits from operating aircraft in international traffic and qualifying pool participation, but not independent engineering and ground-handling services supplied to other airlines. Such services are organised commercial activities unconnected with the airline's own international transportation and therefore remain taxable in India. Cash deposits during demonetisation were treated as explained where deposit slips and accounts showed ordinary airport-counter collections from passengers and cargo agents, the receipts were recorded in the books, no defects were found, and collection patterns were not abnormal. The treaty exemption claim fails, while deletion of the unexplained cash-deposit addition remains undisturbed.

Rectification that enhances an assessment or increases liability requires prior notice and a reasonable opportunity of hearing under section 154(3). Where the record does not establish that notice proposing rectification or enhancement was issued, or that the affected person received an opportunity to be heard, the rectification breaches this mandatory requirement and principles of natural justice. Enhanced additions made through such a rectification order are therefore invalid and must be deleted.

Goodwill arising in a slump sale as the excess of consideration over the net value of acquired assets and liabilities was treated as a newly generated business or commercial right, rather than an asset transferred from the predecessor's depreciable block. Accordingly, restrictions applicable to transferred depreciable assets did not govern the claim, and goodwill remained eligible for depreciation for assessment year 2018-19 because the later statutory exclusion applied prospectively. Non-compete fees were characterised as revenue expenditure allowable as such, not as a depreciable capital intangible asset; depreciation on those fees was therefore unavailable.

Independent diamond grading and certification that provides factual reports on cut, colour, clarity and carat weight does not constitute managerial, technical or consultancy services merely because the provider uses specialised personnel or equipment. Such services do not transfer grading methodology, scientific standards, processes or know-how to the payer and therefore fail the "make available" requirement for fees for included services under the India-USA and India-UK tax treaties. Payments to non-resident grading entities are consequently not taxable as fees for technical services; where no other Indian taxable nexus exists, no tax deduction obligation arises and consequential interest is not payable.

Non-saleable land used for roads and gardens, having nil net realisable value, may be excluded from closing stock where the taxpayer has consistently followed that treatment and the inventory is valued at lower of cost or net realisable value under section 145A. Agricultural rent claimed as agricultural income requires supporting evidence that land was leased to farmers; without such evidence, the claim is not substantiated. A disallowance for expenditure relating to exempt income cannot be made under section 14A where no exempt income was earned during the relevant year.

Section 194-IA excludes transfers of agricultural land from the purchaser's tax-deduction obligation. Where the sale deed described the property as agricultural land and no material showed it fell within an excluded category, no tax was deductible. Section 206AA increases the withholding rate only when tax is otherwise deductible; it does not create an independent obligation. Accordingly, treatment of the purchaser as an assessee in default for short deduction was unsustainable. Interest under section 201(1A), being consequential to the failed principal demand, was also unsustainable and deleted. The cancellation of the sale deed and non-encashment of payment cheques further supported the result.

Income receivable under a trust created by the deceased's sole will falls within proviso (ii) to section 164(1) where it is the only trust so declared. Read with section 167B and the applicable CBDT clarification, this exception prevents taxation of the testamentary family trust's income at the maximum marginal rate. The income is instead taxable as the total income of an association of persons under proviso (ii) to section 164(1).

Reassessment notices issued beyond three years from the end of the relevant assessment year require prior approval from the authority specified under Section 151(ii). Approval by a Principal Commissioner alone does not satisfy this mandatory jurisdictional requirement where approval from the Principal Chief Commissioner or other specified authority is required. A notice issued without such valid approval is without jurisdiction and must be invalidated. The stated analysis confirms that the reassessment notice was invalid for failure to obtain approval from the appropriate authority.

Business-promotion expenditure claimed as secret commission is deductible under Section 37(1) only where the taxpayer proves its nature, genuineness and business purpose through primary particulars and supporting evidence. Failure to provide recipients' identities and addresses, payment dates, payment mode, or documentary proof justifies disallowance, irrespective of whether recipients were private persons or public servants. Where the Tribunal's findings rest on the record and are neither perverse nor unsupported by relevant material, no substantial question of law arises for interference under Section 260A. The claimed expenditure was therefore not allowable as a business deduction.

Reassessment cannot be reopened merely because investigation information shows subsequent cash withdrawals by a payment recipient where the assessee had disclosed and substantiated the underlying purchase transactions in the original scrutiny assessment. Invoices for cotton purchases had already been examined under Section 143(3), while the recipient proprietor's cash withdrawals did not provide new tangible material showing that the assessee's income had escaped assessment. Such reopening constitutes a fishing and roving inquiry and an impermissible change of opinion. The reassessment notice was quashed.

Bogus-purchase additions may be confined to the embedded profit element where suppliers and goods movement are unverifiable, but the assessment does not invoke unexplained-expenditure provisions and the books, recorded sales and disclosed profits remain accepted. On those facts, a 10% estimation of the disputed purchases was treated as a permissible exercise of discretion. Reassessment was also treated as procedurally valid where the notice and record showed compliance with the reopening process; the Assessing Officer need not provide all material at the notice stage. No substantial question of law arose.

Section 80P(2)(d) deduction applies to interest and dividend income from investments with cooperative societies and cooperative banks where the statutory conditions are met. The third proviso allowing unavailed additional depreciation in the immediately succeeding previous year applies from 1 April 2016 and covers Assessment Year 2016-17. Milk cans, artificial insemination equipment and laboratory-testing equipment qualify as plant and machinery for additional depreciation where applicable conditions are satisfied; treatment of milk cans as plant for normal depreciation supports their eligibility. The deductions and additional-depreciation claims therefore remain available for the relevant assessment years.

Non-adjudication of appellate grounds does not justify recall where the Tribunal has already considered and rejected those grounds. The High Court found that the allegedly undecided grounds had been addressed, leaving no basis to interfere with the appellate order. The Supreme Court dismissed the appeal on that basis.

For penalty-only GST appeals arising from proceedings initiated before 1 October 2025, the subsequently introduced proviso requiring a ten per cent pre-deposit under Section 112(8) does not apply retrospectively. The pre-amendment provision required payment of admitted amounts and a prescribed percentage of disputed tax, while the new penalty-specific condition contains no express or necessarily implied retrospective effect. Applying it to earlier proceedings would restrict the vested substantive right of appeal. Accordingly, no pre-deposit is required for admission of the penalty-only appeal.

In transitional real-estate projects, input tax credit (ITC) benefit is project-specific and must be passed on to each eligible purchaser, including purchasers who booked units after GST implementation where post-GST construction inputs were used. Buyer-wise identified recipients must receive the unpassed benefit; deposit in the Consumer Welfare Fund is limited to genuinely unidentifiable recipients. Excess benefit given to some purchasers cannot be set off against amounts due to others. Profiteering includes GST charged on the inflated base price. Interest at 18% per annum is computed from each eligible buyer's last instalment payment until refund. Penalty cannot apply retrospectively to a contravention completed before the penal provision took effect.

Delay in filing a statutory GST appeal may be condoned through writ jurisdiction where an assessment order is uploaded under an incorrect portal category and the assessee therefore does not receive effective notice within the limitation period. Although the Appellate Authority remains bound by the limitation framework under Section 107, denial of a merits hearing in circumstances beyond the assessee's control would cause grave prejudice. The appeal was permitted to be filed within 30 days of uploading of the order, with a direction for merits-based adjudication.

Late fee for failure to file GST returns may be assessed and demanded under Section 73 read with Section 47 of the Central and State GST Acts. The text states that, for the relevant tax period, returns were not filed and a show-cause notice preceded assessment of tax and late-fee liability. Section 47 specifically authorises late fee for non-filing of returns, and no jurisdictional defect in the demand notice was identified. The demand was therefore described as validly made against the assessee.

Consolidated show cause notices and consequential orders cannot validly cover distinct financial years where binding High Court decisions require separate proceedings for each assessment year. A composite notice and order spanning financial years 2019-2020 to 2023-2024 were inconsistent with that principle and were quashed. Separate notices may be issued for the relevant assessment years, with the specified period excluded in computing limitation.

The statutory amnesty mechanism applies where tax liability is accepted but payment has been delayed; it is not available to a taxpayer disputing the basis of the assessment or asserting that no tax is payable. Such a challenge must be pursued through the prescribed statutory appellate remedy. Where the disputed tax had already been recovered, the appeal was to be entertained on merits despite limitation, and further recovery was to remain in abeyance if the appeal was filed within the stipulated period.