Business expenditure remains deductible where profit and loss accounts, purchase records, VAT returns and sales records establish that the underlying receipts and costs arose from business transactions. Incorrectly reporting those receipts and expenses under income from other sources in the return constitutes a return-preparation error and does not alter their true business character. The claimed expenditure was therefore allowable as business expenditure, and the disallowance was deleted.

Interest paid on bank and non-banking financial company borrowings used to advance loans was deductible from income from other sources where the assessment record established a direct nexus between the borrowings, the loans advanced to private parties, and the interest income earned. Interest expenditure incurred to generate declared interest income was allowable under the applicable deduction provision. The corresponding disallowances for both assessment years were deleted.

Assessment against a person other than the searched person under the search-assessment framework depends on the date seized material is handed to that person's Assessing Officer. Where handover and satisfaction occur on or after 1 April 2021, that framework is excluded and reassessment is the prescribed route; the notice and consequential assessment were quashed for lack of jurisdiction. Penalty limitation for a matter not linked to assessment proceedings begins when the Assessing Officer refers the matter for penalty action. As the penalty order was passed after the applicable six-month period, the penalty for accepting prohibited loans or deposits was time-barred and quashed.

Recurring digital marketing and platform-facilitation expenditure incurred to promote an existing business is revenue expenditure where it creates no asset or advantage in the capital field. Digital advertising, media management, search-engine optimisation, SMS broadcasting, content generation, video production and social-media strategy required repeated promotional spending and merely improved customer traffic, sales and commission income; the expenditure was allowable under Section 37. Payments for digital-platform search and product-display services similarly enabled product visibility, corrected search terms and improved customer access without procuring a capital asset or enduring capital advantage; they were also allowable under Section 37. The enduring-benefit test applies commercially, not mechanically.

Section 194N places the obligation to deduct tax at source on the banking company making cash payments beyond the prescribed threshold, while Section 271C penalises the person that fails to make that deduction. A customer receiving cash is not liable for the bank's deduction failure or related penalty. A bank therefore lacks statutory authority to impose a lien on a customer's current account to recover alleged tax deducted at source on cash withdrawals, particularly where no tax-authority direction exists. The lien must be released and account operations permitted upon furnishing relevant income-tax returns.

Share capital received from four investors could not be treated as unexplained cash credit where scrutiny assessments of those investors had accepted the sources of their investments and made no additions in their hands. The Tribunal treated the investments as genuine in the recipient company's hands on the basis of the assessment records. That factual finding disclosed no infirmity or substantial question of law, rendering the share-capital addition under Section 68 unsustainable.

Revision under Section 263 requires the assessment order to be both erroneous and prejudicial to Revenue interests. Explanation 2(a) covers assessments made without necessary inquiry or verification, but does not remove the requirement to establish both conditions. Where the Assessing Officer sought and received details on unsecured loans and trade payables, examined the explanations, and adopted a plausible view, revision cannot rest solely on audit objections or a preference for further verification. Absent material showing Revenue prejudice, revision is invalid.

Carry-forward and set-off of business losses require a valid loss return under Section 139(3) and determination of the loss through the relevant assessment process. Failure to file returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for continued carry-forward under Sections 72, 80, 139(3) and 157. Consequently, an earlier-year business loss could not be set off against income of the later assessment years under consideration.

Reassessment initiated beyond four years requires established failure by the assessee to make a full and true disclosure regarding the income alleged to have escaped assessment on the recorded reasons. Where no addition survives on either recorded ground-recomputation of Section 14A disallowance or alleged NSEL income-an addition on a separate issue lacks jurisdictional support. Explanation 3 to Section 147 permits assessment of another escaped-income issue discovered during valid reassessment proceedings, but does not cure an invalid reopening or enlarge the substantive jurisdiction under Section 147. The reassessment and the unrelated addition could not survive.

Contribution towards augmentation of an electricity transmission line owned and maintained by the electricity board was treated as revenue expenditure where it secured adequate power supply for an existing business without conferring ownership, possession, or an enduring capital advantage. The board retained ownership, maintenance responsibility, and the ability to supply other consumers. The expenditure was incurred wholly and exclusively to improve business efficiency and profitability. Revision was not sustainable because the Assessing Officer had made enquiries and correctly allowed the deduction; the assessment was therefore neither erroneous nor prejudicial to Revenue interests.

Business expenditure incurred wholly and exclusively for road and bridge projects in the ordinary course is deductible under section 37(1), even where no corresponding income is booked for a particular project. Absence of project-specific income does not itself invalidate the expenditure; the relevant enquiry is whether taxable receipts or income escaped recognition. Income from one project had been recorded, and identical findings for the preceding assessment year had attained finality. The disallowance was therefore deleted, sustaining deduction of the infrastructure-project expenditure.

Losses of an undertaking eligible for deduction under Section 10B remain available for set-off against taxable profits of other undertakings and for carry-forward under the general loss provisions. Section 10B requires separate computation of export profits solely to quantify the deduction for each eligible undertaking; it does not alter the treatment of that undertaking's profit or loss in computing combined income. Rules governing aggregation, inter-source and inter-head set-off, and carry-forward therefore continue to apply.

TDS on payments to non-residents was considered where the ITAT found that payments to three non-resident companies were not royalty under the applicable DTAA. The High Court dismissed the Revenue's appeal but allowed the Revenue to seek review or restoration if its review petition concerning Engineering Analysis Centre of Excellence succeeds before the Supreme Court. The Supreme Court disposed of the petition and related pending applications.

PTFE braided gland packing with a cross-sectional dimension exceeding 1 mm is excluded from Section XI by Note 1(g), despite its braided form and industrial sealing use. As it does not qualify as textile material, it cannot be classified as a textile article for technical use under heading 5911. The residual PTFE classification under HSN 39209949 applies to PTFE products other than rigid or flexible plain sheets. Clear tariff headings, Section and Chapter Notes, and HSN Explanatory Notes prevail over industry practice or trade parlance. The packing falls under Schedule II and attracts GST at 18%.

GST-rate reductions must be passed to recipients through commensurate price reductions under the anti-profiteering framework. Retaining the same tax-inclusive cinema ticket price by increasing the base price after a GST reduction allows the supplier to retain the tax benefit and breaches that obligation. Regulatory directions or permissions concerning permissible cinema fares do not create an exception to the separate duty to pass on the tax benefit. Profiteering is quantified by retaining the pre-reduction base price, applying the reduced GST rate, comparing that commensurate price with actual prices, and calculating the excess collected on relevant sales. Where recipients are unidentifiable, the amount with applicable interest is credited equally to the Central and State Consumer Welfare Funds; no penalty applies for the investigation period.

GST rate reduction on cinema admission tickets had to be passed to recipients through a commensurate price reduction under the anti-profiteering provisions. Maintaining the existing cum-tax ticket price by increasing the base price defeated the tax benefit and breached that obligation. Regulatory fare limits, High Court permission to collect proposed fares, and representations to licensing authorities did not override the independent duty to reduce prices. Profiteering was computed by retaining the pre-reduction base price, applying the reduced GST rate, and measuring excess collections on actual ticket sales. The quantified benefit, with applicable interest, was directed to designated consumer welfare funds because recipients were unidentifiable; no penalty applied for the investigation period.

Section 129(3) requires a penalty order in detention proceedings to be issued within seven days of service of the detention notice. The mandatory term "shall", the coercive nature of detention and penalty proceedings, and strict construction of fiscal law support treating this period as binding. Where the relevant dates are undisputed and on record, the limitation objection may be raised before the Tribunal. E-invoices, reported supplies and tax payment may also negate an inference of intent to evade tax merely from the absence of an e-way bill. A penalty order issued after the prescribed period is time-barred, illegal and without jurisdiction, invalidating the consequential appellate order.

Stock transfers between premises bearing the same GSTIN, undertaken under a delivery challan without consideration or a distinct counterparty, do not constitute supplies and do not attract GST. Consequently, the tax-linked penalty mechanism under Section 129 cannot apply where no tax is payable. Although an e-way bill may be required for movement of goods for reasons other than supply, its absence in such circumstances is a document-related contravention subject to the specific applicable penalty provision, rather than Section 129. This treatment applies where there is no material indicating fraud, suppression, or non-genuine movement.

Common show-cause notices under Section 74 covering multiple financial years are treated as permissible, following a coordinate-bench view that restored notices and original orders previously quashed solely for combining years. Challenges to both original tax orders and appellate orders must be pursued through the statutory appeal before the Goods and Services Tax Appellate Tribunal. Quashing tax proceedings merely because a notice covers multiple financial years is therefore unsustainable, while substantive objections remain available through the appellate mechanism.

Article 226 writ jurisdiction may be exercised to condone delay in filing a statutory appeal against GST registration cancellation where strict application of the appellate limitation would deny an effective remedy. Although section 107 restricts the Appellate Authority's power to extend time beyond the prescribed limit, writ relief may be appropriate where cancellation affects business continuity and the taxpayer seeks to regularise statutory compliance. On the stated facts, the delay was condoned and the appeal was directed to be entertained and adjudicated on merits.