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.

Section 148A(1) requires disclosure of information suggesting escaped income, but not the source from which that information was obtained; a notice and annexure sufficiently identifying the proposed reassessment basis enable an effective response. A determination under Section 148A(3) must nevertheless examine an assessee's material claim that the income proposed for reassessment was already included and taxed in an earlier assessment year. Addressing only the abstract taxability of the amount, without verifying prior inclusion from available returns and supporting material, is insufficient and vitiates the reassessment decision-making process.

TDS credit must be granted, with consequential relief, where deduction from the assessee's income is verified even if the deductor failed to remit the tax to the Central Government. Section 205 protects the assessee from recovery of tax already deducted, and an insolvency claim against the deductor for unpaid receivables does not bar the credit claim. An intimation determining tax payable is enforceable as a demand only upon mandatory service on the assessee. Where service cannot be proved, the demand cannot support recovery proceedings or adjustment of refunds under Section 245.

Refunds crystallised after TDS assessment or appellate relief constitute vested rights payable with applicable interest. Sections 200A and 201 operate separately: processing and adjustments of TDS statements under section 200A may involve Rule 31A and Form 26B, but those requirements do not govern refunds determined under section 201 or appellate orders. Form 26B cannot therefore be made a compulsory condition for such refunds. Outstanding demands against the assessee or related TANs cannot justify withholding or adjusting the refund unless a valid adjustment order is passed under section 245.

Revisional jurisdiction does not arise where an assessment allowing deduction for interest on advances to members contains no error prejudicial to revenue interests. The deduction was restricted to the assessee's gross total income, while the record did not establish that interest from fixed deposits with a non-cooperative bank had been claimed as deductible. Nor did it support allocating expenditure to further restrict the deduction. The revisional order therefore lacked jurisdiction, and the assessment order remained valid.

Pending statutory appeals against reassessment proceedings must be decided within 12 weeks where they raise objections to the validity of sanction and the absence of a mandatory Document Identification Number in approval. The appellate authority must consider these grounds, including additional grounds, in the statutory appellate process. No merits determination was made on whether the sanction had been granted by the correct authority or whether the approval was defective for want of a Document Identification Number.

Penalty for concealment or furnishing inaccurate particulars cannot survive where the sole underlying bad-debt disallowance has been deleted and that deletion stands confirmed. With no surviving tax addition, there is no basis to sustain penalty in respect of alleged concealment or inaccurate particulars linked to that addition. Penalty under Section 271(1)(c) was therefore deleted in favour of the assessee.

Statutory housing boards performing housing-development functions can pursue objects of general public utility and remain eligible for tax exemptions under Sections 11 and 12. Recovery of charges for public statutory functions does not by itself make the activity commercial; its character depends on the statutory objects, functions, regulatory controls, nature of receipts, and whether charges substantially exceed costs with only a nominal mark-up. Section 2(15), read with Section 13(8), therefore does not deny charitable-exemption benefits where housing activities continue to serve public functions.

Section 90(2) gives priority to a Double Taxation Avoidance Agreement where its provisions are more beneficial to the assessee. Section 206AA operates as a procedural tax-withholding requirement and does not displace a beneficial treaty rate for payments to non-residents. Tax need not be deducted at the higher rate solely because the non-resident deductee has not furnished a permanent account number when the applicable treaty prescribes a lower rate. The treaty rate consequently governs tax deduction at source in such circumstances.

Article 226 writ jurisdiction is discretionary and ordinarily should not be used to challenge reassessment proceedings where the reassessment order itself is not impugned and the taxpayer has already pursued a pending statutory appeal against that order. Invoking an effective statutory remedy for the same cause precludes parallel proceedings seeking substantially the same relief through writ jurisdiction. The reassessment challenge is therefore not maintainable, and no writ interference is warranted while the statutory appeal remains pending.

Fresh Isabgol seed exemption depends on the condition of psyllium seeds when supplied. Psyllium seeds classified under tariff item 1211 90 13 qualify for the heading 1211 exemption only if fresh or chilled; intentionally dried goods attract 5% GST. Procurement through APMC auctions and storage in dry, ventilated godowns were treated as drying, while no evidence established that the seeds remained fresh between harvest and onward supply. Consequently, the supplies do not qualify for the exemption for fresh Isabgol seeds and are taxable at 5%.

GST on processing brass statues and qualifying wooden handicrafts is 5% where goods belong to a registered recipient and the finished goods are predominantly handmade by craftsmen; processing goods of an unregistered person falls under the residual service entry at 18%. Commercially cast or moulded resin statues and ornamental vases are plastics articles, classified under tariff items 3926 40 29 and 3926 40 99 respectively, rather than as original sculptures under heading 9703. Marble and wooden idols of a god or goddess are GST-exempt from 22.09.2025; the exemption excludes decorative non-deity figures and does not depend on a particular eight-digit tariff classification.

Mandatory pre-movement E-Way Bill generation under Rule 138(1) applies to taxable goods exceeding the prescribed consignment value. Absence of the E-Way Bill at interception is treated as substantive non-compliance because online generation is a statutory mechanism for monitoring goods movement; later production does not cure the lapse. A short inter-State route, the nature of the goods, post-interception generation, and repetition of the lapse may collectively indicate an intention to evade tax rather than a technical or procedural error. On those facts, detention, tax and penalty provisions may be invoked.

E-way bill compliance applies to movement of goods, including movement otherwise than by way of supply, unless a specified exemption is satisfactorily established. Transporting an owned excavator back to registered premises under a delivery challan does not, by itself, remove that requirement. A claimed short-distance exemption must be supported by evidence of its applicability. Absence of evidence on consideration received for use of the excavator and corresponding GST treatment, combined with transport without an e-way bill, supports an inference of intent to evade tax rather than a merely procedural lapse. Penalty for the movement was therefore justified.