Documented share acquisition, holding and sale through banking channels, demat records and a recognised stock exchange support the genuineness of long-term capital gains where Revenue produces no contrary material. An approved SME market maker's subscription, allotment, demat credit, market-making agreement and exchange-recorded transactions established genuine activity; gains could not be treated as unexplained income under Section 68 and qualified for exemption under Section 10(38). A commission-expenditure addition under Section 69C cannot survive where it rests solely on an unsubstantiated allegation that genuine share gains were accommodation entries and no evidence of commission payment exists.

Section 153(6) allows twelve months from the end of the month in which the appellate order is received or passed by the specified senior income-tax authority. Delivery of a Tribunal order to the Departmental Representative is treated as internal transmission, and without proof of delivery to the proper authority, limitation is not established. Purchases cannot be treated wholly as unexplained expenditure where VAT verification, stock and movement records, supplier existence, and corresponding sales substantiate them. Non-response by some suppliers to summons, without addressing that independent material, does not justify an addition of the entire purchase value; only suppressed profit may be estimated where supported.

Section 69A additions for cash found during search cannot be sustained where ownership is supported by an untested affidavit, cash accounts showing balances, withdrawals and receipts, and identifiable sources, with no contrary evidence rebutting the explanation. Jewellery found in a joint family household is treated as explained where the search-time valuation places it within the aggregate limits under CBDT Instruction No. 1916. Accordingly, plausible and unrebutted evidence of source, together with jewellery within applicable household limits, prevents an addition for unexplained assets.

Section 153A jurisdiction depends on whether the relevant assessment year falls within the statutory block period computed from the assessment year relevant to the search. For a search conducted on 30 June 2019, the relevant year was treated as Assessment Year 2020-21. Applying the jurisdictional High Court's method for computing the permissible ten-year block, Assessment Year 2010-11 fell outside that period. Consequently, assumption of jurisdiction under Section 153A was invalid and the assessment for that year was quashed.

TDS credit may be granted to a person other than the deductee where the related income is assessable in that person's hands under Section 199 read with Rule 37BA. Where merger-related business income is substantively assessed in the successor's hands, the corresponding TDS credit supports refund interest under Section 244A(1) from the first day of the relevant assessment year until refund. Excluding any period of interest on the ground of delay attributable to the taxpayer is exceptional under Section 244A(2) and requires determination by the prescribed higher authority; the Assessing Officer cannot unilaterally deny interest for that period.

Audited books cannot be rejected under Section 145(3) merely because some persons fail to respond to third-party verification notices, absent identified defects, accounting irregularities, or material discrepancies. Where the assessee provides details of over 4,000 persons and available particulars are verified, non-compliance by selected persons alone is insufficient. Income from an HR-outsourcing business also cannot be estimated at a fixed percentage of gross receipts without separating salary and statutory reimbursements, which are pass-through costs, from actual income and establishing a rational factual basis. Rejection of books and the resulting addition were therefore unjustified.

Unexplained cash-credit additions based on alleged accommodation entries require transaction-specific evidence. Where an executed property-sale agreement, banking records, payer tax records, confirmations, payment documentation, correspondence, and contractual refund evidence establish commercial substance, general search material concerning purported entry providers does not justify treating the receipt as unexplained. A commission-expenditure addition premised solely on the alleged accommodation entry also lacks a factual basis once the underlying receipt is shown to be genuine. The additions were therefore deleted.

Section 143(1)(a) summary adjustments may be challenged in an appeal against a section 143(3) assessment where the adjustment remains embedded in assessed income without independent scrutiny. Employees' PF/ESI contributions should not be disallowed through summary processing where allowability was legally debatable when the intimation was issued; later judicial settlement does not retrospectively make the issue apparent from the return. For section 14A read with Rule 8D, computation should consider only investments that yielded exempt income during the relevant year. No additional disallowance is warranted where the taxpayer's voluntary disallowance exceeds that computation, and an unsupported addition cannot adjust book profit under section 115JB.

Verified purchase expenditure accepted in consequential assessment proceedings binds the Department on the remanded issue. Once the Assessing Officer examined the purchases, accepted the returned income and allowed the full expenditure claim, no basis remained to sustain a disallowance previously treated as unsubstantiated or inflated. The purchase disallowance partly retained at the first appellate stage was therefore deleted in full, and the Revenue's related grounds failed.

Section 54 exemption should be construed liberally where capital gains are invested in a new residential house within the prescribed period. Investment in a fifty per cent share of a new residential property before the extended return-filing date, exceeding the capital gain, constitutes substantive compliance. Failure to deposit the unutilised amount in the Capital Gains Account Scheme by the due date under section 139(1) is a procedural lapse that does not defeat the exemption when the investment is genuine and timely. The section 54 deduction was therefore available, and the disallowance was deleted.

Reassessment cannot be initiated merely to revisit a deduction for in-house scientific research when the claim, supporting registration certificate and research-and-development expenditure had already been furnished, examined and accepted in the original scrutiny assessment. Material relied on for notice and reassessment proceedings that was already available to and considered by the Assessing Officer cannot support a fresh assessment merely because a different view is later taken. Such reassessment amounts to an impermissible review based solely on change of opinion and is invalid.

Reassessment under Sections 147 and 148 cannot be used to revive scrutiny proceedings that lapsed because no final assessment order was completed within the period prescribed by Section 144C(4). Transfer-pricing adjustment and additional-depreciation disallowance had already been examined and included in the draft assessment order, while no fresh material indicated income escaping assessment. Reopening on identical material would improperly extend the statutory time for completing the original assessment and allow the Revenue to benefit from its failure to finalise that assessment. Reassessment in those circumstances is impermissible.

Share premium received on a fresh allotment of equity shares to a non-resident is a capital receipt and is not taxable as income unless an express charging provision applies. The deeming provision for excess share premium was limited to amounts received from residents and did not cover a non-resident shareholder; the relevant departmental instruction on capital-account transactions bound income-tax authorities. Reassessment based on an alleged sale or transfer is invalid where the material establishes a fresh allotment. Reliance on lack of genuineness without raising that ground in the show-cause notice or allowing a response also breaches natural justice.

Condonation of delay in furnishing Form 10B for an exemption claim should be decided pragmatically where pandemic-related circumstances establish genuine hardship. Furnishing the audit report is procedural, and the report may be produced before the assessment or appellate authority upon sufficient cause. Delegated discretion under Section 119(2)(b) must advance substantial justice rather than deny relief on technical grounds. An 18-day Covid-19-related delay was accepted as genuine; rejection of condonation was therefore invalid, requiring the delayed Form 10B to be treated as filed within the prescribed period and considered for the exemption claim.

Assessment jurisdiction could not be challenged on the alleged absence of a transfer order under Section 127(2), where the assessee had given no objection to centralisation. The Principal Commissioner passed a centralisation order, communicated it by letter and uploaded it on the portal. As the assessee did not rebut these facts through a rejoinder, the uncontroverted material defeated the jurisdictional objection. The challenge to the assessment jurisdiction was therefore not sustainable.

Computation of non-life insurance business profits under Section 44 and Rule 5, the application of Section 14A, withholding obligations on payments to non-resident surveyors and reinsurers, disallowance for non-deduction of tax, UPS depreciation, minimum alternate tax for insurers, and consistency in assessments were identified as the substantive tax issues. The High Court had answered the admitted questions largely for the assessee. The Supreme Court dismissed the Special Leave Petition because of inordinate delay and the absence of a plausible, bona fide explanation for condonation; it did not adjudicate those substantive issues.

Documented DRC-03 reversals, supported by electronic cash and credit ledger debits, reconciliation statements and DRC-04 acknowledgement, establish reversal of disputed excess input tax credit. A blank optional reasons field in DRC-03 does not invalidate the reversal. Section 16(5) removes the time-limit objection under Section 16(4) for the specified financial years. Interest and penalty on any residual demand require separate computation after hearing, and liability arising from relevant Section 73 demands may qualify for waiver under Section 128A subject to prescribed compliance.

Accumulated input tax credit refund is admissible where statutory credit conditions are met and export transactions are supported by e-way bills, transport records, shipping documents, exporter confirmations and banking records. Goods need not commence movement from the direct supplier's registered premises, and toll-plaza data is not a mandatory condition for credit. Cancellation or alleged irregularities involving suppliers beyond the direct supplier do not, without evidence attributable to the exporter, justify denial. Fresh allegations concerning licensing or investigations, and unsupported additional material not raised in the show cause notice or earlier proceedings, cannot be introduced before the Tribunal unless the prescribed exceptional grounds for additional evidence are established.

Rule 96(10) of the CGST Rules, retrospectively introduced from 23 October 2017, was treated as ultra vires Section 16 of the IGST Act and manifestly arbitrary. Its omission from 8 October 2024 without a saving clause applies to pending, non-final proceedings founded on that rule. Consequently, a pending show-cause notice based on Rule 96(10) cannot continue, and the affected exporter is entitled to refund of IGST with applicable interest.

Clause 7 of the notification dated 8 October 2024 requires compliance with natural justice where a rectification order adversely affects a person. Rejecting a rectification application without affording the assessee an opportunity of hearing breaches that requirement. The rejection is consequently invalid and must be quashed, with the rectification application reconsidered under Clause 7 and section 16(5) of the CGST Act, 2017.