Release of seized gold jewellery was linked to the statutory requirement of a show-cause notice before confiscation, including issues of waiver of notice and personal hearing under Section 124. The special leave petitions challenging non-compliance with that requirement were dismissed because a coordinate Bench had dismissed an identical special leave petition. The dismissal left the challenged position undisturbed without setting out any further substantive determination on the notice, confiscation, or waiver issues.

Property purchased by a father in the names of his minor children falls within the child exception under the Prohibition of Benami Properties Act where the 2016 amendments apply retrospectively as declaratory, procedural, curative and machinery provisions. The father-minor child relationship also constitutes a guardian-ward fiduciary relationship under the unamended fiduciary-capacity exception. Consequently, a suit asserting rights in such property is not barred by the Benami law and the plaint is not liable to rejection.

Transfer-pricing benchmarking under the Resale Price Method permits an associated enterprise to be selected as the tested party where it is the less complex entity and reliable margins from comparable uncontrolled transactions are available. Merchant-trading transactions involving back-to-back USD purchases and sales, letters of credit, insignificant working-capital needs and limited inventory, credit, market and foreign-exchange risks supported that selection. A single material comparable invoice may be used under Rule 10B(1)(b). Manufacturing comparables with materially different functions, assets and risks were unsuitable, resulting in acceptance of the Resale Price Method analysis and no adjustment beyond the taxpayer's voluntary adjustment.

Faceless reassessment jurisdiction under Section 151A requires a notified scheme authorising faceless assessment, reassessment and issuance of income-escaping assessment notices. Where the notice under Section 148 and consequential statutory, show-cause and reassessment proceedings were initiated and substantially conducted before notification of the e-Assessment of Income Escaping Assessment Scheme, 2022, the statutory authority to proceed facelessly was unavailable when jurisdiction was assumed. Passing the reassessment order after notification does not cure that defect. Such proceedings and the resulting reassessment order are void ab initio and bad in law.

Separate transfer-pricing adjustment for interest on overdue receivables from an associated enterprise may be warranted even where the underlying IT-enabled services transaction falls within the arm's-length tolerance range. Receivables representing an abnormal credit period beyond the contractual 90 days require independent consideration where the credit-period impact is not adequately reflected in the service price. The principle that receivables are closely linked to the principal transaction applies only when, after a credit-period adjustment, the transaction price remains at or above the arm's-length price. Interest beyond the agreed credit period may therefore be benchmarked at LIBOR plus 200 basis points.

Repayment of recorded micro-finance loan receivables, supported by audited disclosures, cash-book entries, cash-flow details, deposit particulars and borrower confirmations, does not create a fresh unexplained cash credit. Receipt in demonetised currency and non-service of some third-party notices do not establish undisclosed income without material disproving the repayments, particularly where the books and loan portfolio remain unrejected. Interest embedded in the instalments, already credited in the books and offered to tax, cannot be separately added once the principal recoveries are accepted; such addition would duplicate taxation.

Section 80-IA(8) requires inter-unit transfers to be examined at market value when computing profits of an eligible cogeneration undertaking. Low-pressure steam extracted and supplied to a paper division remains a commercially useful, measurable output of the integrated process, carrying common fuel, boiler, labour, maintenance, depreciation and related costs despite requiring no additional fuel after extraction. Assigning nil cost to that steam and charging all common costs solely to electricity revenue is impermissible without determining an alternative market value or identifying defects in the recorded value. Where verified records support the disclosed allocation, the eligible undertaking's reported profit and resulting section 80-IA deduction are to be accepted.

Reassessment initiated for alleged escaped capital gains cannot be sustained solely on additions for notional annual letting value or reclassification of disclosed rental income when no addition is made to the income forming the basis for reopening. Where the assessee was only a confirming party to a transfer of tenancy rights, neither transferred immovable property nor received consideration, and the alleged capital gains were not assessed, the Assessing Officer cannot uphold reassessment through unrelated income-from-house-property additions. The reassessment was therefore without jurisdiction and quashed in favour of the assessee.

Reassessment beyond three years requires satisfaction of the statutory escaped-income threshold and approval from the competent higher authority. For assessment year 2019-20, the recorded escaped income was below the threshold required to invoke the extended reassessment period, while approval was granted by an authority not competent after the three-year period. These discrepancies showed non-application of mind, invalidated the sanction, and rendered the reassessment notice and consequential assessment void.

Revisionary jurisdiction cannot be exercised where a reassessment has specifically examined alleged penny-stock share transactions and accepted the returned short-term capital gains after verification. Contract notes, broker and ledger details, bank statements, and other supporting material established that the Assessing Officer had conducted inquiry and considered the evidence. The assessment represented a plausible view based on inquiry and verification; therefore, it was neither erroneous nor prejudicial to the interests of the Revenue. The deeming fiction applicable to cases lacking inquiry did not apply, rendering the revision order unsustainable.

Foreign-currency loans repayable in US dollars are benchmarked by reference to LIBOR, with LIBOR plus 300 basis points treated as appropriate. Under the transactional net margin method, comparable companies require meaningful functional and product comparability; entities engaged in distinct engineering procurement and construction activities or manufacturing materially different products should be excluded. No separate arm's-length interest adjustment arises on delayed associated-enterprise receivables where no interest is charged to related or unrelated parties and margins are embedded in pricing. Section 14A read with Rule 8D does not permit a disallowance where no exempt income is received or accrues during the relevant year.

AMP expenditure included in operating costs for interconnected international transactions benchmarked under TNMM cannot be separately subjected to an arm's-length adjustment where accepted net margins already absorb that cost; separate benchmarking without proper segregation would distort the selected method, and the Bright Line Test does not support a protective adjustment. A separate interest adjustment on outstanding receivables requires verification of whether working-capital adjustments already reflected the impact, to prevent duplication. A mismatch between returned income and Form 26AS receipts requires factual examination where receipts are claimed to belong to associated enterprises, including evidence relating to their Indian assessment and mutual agreement procedure.

Advertising, marketing and promotion expenditure constitutes an international transaction under Chapter X only where tangible material establishes an arrangement or understanding requiring expenditure for brand promotion on behalf of associated enterprises, together with its transaction price. The Bright Line Test has no statutory basis to establish either the existence of such a transaction or its arm's length price. Where no such arrangement is established and the assessee's other international transactions are accepted at arm's length, neither a substantive Cost Plus Method adjustment nor a protective Bright Line Test adjustment survives; both adjustments are deleted.

Expense disallowance in a high-volume petrol and diesel outlet business must reflect the business's consistently low profit and gross-profit margins. Where some expenditure remains unsubstantiated, an ad hoc disallowance that produces an abnormal margin disproportionate to the business is not reasonable. Restricting the disallowance to 5% was considered appropriate instead of 10%, resulting in relief for the assessee.

Foreign leave travel concession is not exempt from salary taxation and must be included in taxable salary for tax deduction at source. An employer's statutory deduction obligation remains distinct from recovery of tax from employees; judicial restraint on employee recovery does not itself remove that obligation, particularly where no restraint operates. Failure to deduct tax may result in treatment as an assessee in default. Interest for non-deduction is consequential and mandatory, although its computation or recovery may be reconsidered for periods covered by judicial stay or where employees have discharged their tax liability through self-assessment tax.

A notice under section 148 issued by an Income-tax Officer without pecuniary jurisdiction is inherently invalid where CBDT Instruction No. 1/2011 assigns cases exceeding the prescribed returned-income threshold to an Assistant Commissioner or Deputy Commissioner. The territorial-jurisdiction objection limitation under section 124(3) does not apply to a defect in pecuniary jurisdiction. Such lack of authority is not a procedural irregularity and cannot be cured by section 292BB. Consequently, the section 148 notice and the resulting reassessment are void from inception.

Documented purchases cannot be disallowed as bogus solely because suppliers later become non-compliant, untraceable, or have GST registrations cancelled. Contemporaneous contracts, purchase orders, invoices, delivery and manpower records, e-way bills, banking trails, GST entries, and evidence of use in executed works establish actual receipt where no evidence links the purchaser to a sham transaction or payment recycling. Supplier-side defaults require action against suppliers and do not negate supported procurement. Reliance on incomplete or irrelevant third-party statements breaches natural justice, particularly where books are not rejected. An addition for an alleged transaction cannot stand without verification where the purchaser denies that any transaction occurred; a purchaser need not prove a negative fact.

Profit attributable to an Indian permanent establishment from offshore equipment supplies was assessed at 3.75% by relying principally on findings concerning another group entity. A 2.5% profit attribution was considered reasonable on the available record and was accepted to avoid further litigation. Accordingly, the attributable profit is computed at 2.5% rather than 3.75%, reducing the taxable profit allocated to the Indian permanent establishment.

Pecuniary jurisdiction under CBDT Instruction No. 1/2011 requires a non-corporate assessee reporting income above the prescribed threshold to be assessed by an Assistant Commissioner or Deputy Commissioner. Notices for scrutiny issued by an Income-tax Officer outside that assigned monetary jurisdiction are inherently invalid. The restriction on raising territorial-jurisdiction objections does not apply to a defect in pecuniary jurisdiction. Such a jurisdictional defect is not a procedural irregularity capable of validation through deemed service or participation provisions, rendering the consequential assessment void ab initio.

Capital gains of a charitable trust are treated as applied to charitable purposes when the net consideration from transferring a trust-held capital asset is used to acquire another capital asset. Deposits with a scheduled bank, including savings-bank balances and fixed deposits, constitute distinct debtor-creditor assets rather than cash merely retained by the depositor. Consequently, fixed deposits qualify as new capital assets regardless of their tenure or whether they were made after the financial year-end, and scheduled-bank savings-account balances also qualify for the capital-gains exemption.