Revisionary jurisdiction under Section 263 requires a legally valid assessment order as its foundation. Where the reassessment notice under Section 148 is issued after expiry of the limitation period prescribed by Section 149(1)(b), the resulting reassessment under Sections 147 and 144B lacks legal validity. Electronic proceedings records may establish the actual date of issue despite inconsistent dates recorded in assessment or revision orders. Consequently, revision under Section 263 cannot be sustained when it is founded on an invalid, time-barred reassessment order.

Deduction under section 80P is admissible on business profits enhanced by disallowance of expenditure debited to the profit and loss account. Circular No. 37/2016 recognises that disallowances related to an eligible business increase the profit base for Chapter VI-A deductions. Where provisions claimed as expenditure are disallowed and thereby increase business income, the resulting enhanced profit qualifies for the section 80P deduction.

Deduction for special reserves is confined to the prescribed percentage of profits derived from eligible housing-finance business. Interest expenditure must be apportioned between eligible and non-eligible businesses using their respective turnover when computing eligible-business profits. Complete disallowance is inappropriate; where the taxpayer's allocation basis is not available from the record, the computation requires verification under the turnover-based allocation method.

Addition for alleged undervaluation of imported paper cup machines under Section 69 could not be sustained after CESTAT set aside the customs valuation finding underlying it. No appeal was filed against the CESTAT order concerning the assessee, while the customs appeal involving comparable imports was non-maintainable. With no independent evidence of undervaluation beyond customs information that no longer supported the allegation, deletion of the Section 69 addition was upheld.

Interest under Section 234A is mandatory and remains chargeable despite pending quantum proceedings. Its amount depends on the income ultimately determined in the quantum appeal. Once taxable income is finally settled, the interest liability must be recomputed and adjusted to conform to that determination. The chargeability of interest is therefore maintained, while its final quantum remains contingent on the outcome of the income determination proceedings.

Income surrendered during a survey for excess cash, stock discrepancies, unrecorded creditors, debtors and construction investment remains business income where the taxpayer's sole demonstrated source is its electrical and electronic goods business, no independent non-business source is shown, and the survey disclosure links the amounts to business activities. Incomplete books requiring reconciliation of cash and stock discrepancies do not, on those facts, justify characterising the amounts as unexplained investment or unexplained money under sections 69 and 69A. The deemed-income rate under section 115BBE consequently does not apply.

Reassessment initiated to verify the source of investment in immovable property cannot support an addition on a separate issue where the disclosed source is accepted and no income is assessed on the recorded reopening ground. An addition for the difference between stamp-duty value and actual purchase consideration under Section 56(2)(vii)(b) was therefore deleted. The reassessment scope remained tied to the issue forming the basis for reopening, preventing a surviving addition based solely on stamp-duty valuation differences.

Revisionary proceedings require a meaningful and effective opportunity of hearing before an assessment is treated as erroneous and prejudicial to Revenue interests. Uploading a revision notice shortly before the scheduled hearing and passing the revisionary order immediately thereafter does not provide adequate time to respond. Such procedure breaches the principles of natural justice, rendering the revisionary order invalid and requiring a fresh reasonable opportunity of hearing.

Section 270A permits a 200% penalty for under-reporting only where the income results from misreporting within a specified circumstance under section 270A(9). Withdrawal during assessment of an inadmissible section 80IAC deduction, claimed after an erroneous selection of the old tax regime despite opting for section 115BAA taxation, does not itself establish misrepresentation or suppression of facts. The Assessing Officer must identify and prove the applicable statutory misreporting circumstance. Applying strict interpretation to penal provisions, the enhanced penalty for under-reporting resulting from misreporting was unsustainable.

Transfer-pricing treatment of related-party balances permits netting overdue receivables against overdue payables when both arise with the same associated enterprise and relevant details are available; where payables exceed receivables, no notional-interest adjustment survives. Foreign-currency external commercial borrowings require LIBOR-based interest benchmarking, with the spread determined by tenure and risk; LIBOR plus 200 basis points was retained on consistency. Royalty cannot be assigned an arm's length price of nil through a benefit test outside prescribed methods when technical support is established. Entity-level TNMM aggregation with connected transactions supported the royalty payment, as the taxpayer's margin exceeded comparables, rendering the nil-price adjustment unsustainable.

External development charges paid to the Haryana Urban Development Authority before financial year 2017-18 constituted payments to a contractor for external development works under an arrangement with the State Government. Tax was therefore deductible at source under Section 194C even without a formally executed contract between the payer and the Authority. The Authority did not qualify as Government for the tax-deduction exemption, and no exemption or lower-deduction certificate applied. Non-deduction consequently rendered the payer an assessee in default, with liability under Sections 201(1) and 201(1A).

Transfer-pricing comparability must reflect prevailing market conditions and material differences affecting profitability. COVID-related conditions may make benchmarking a tested party's single-year profit level indicator against comparables' weighted average margins for multiple years inappropriate; contemporaneous single-year data should then be used. Proposed comparables require fresh evaluation where submissions and supporting material have not been properly considered. Intra-group technical, operational and consultancy services should not be assigned a nil arm's length price without properly examining agreements, invoices, email extracts and other evidence of service receipt. The transfer-pricing study should be redone after considering the taxpayer's evidence and submissions.

Failure to adjudicate a specifically raised ground challenging recharacterisation of IT and ITeS services as knowledge process outsourcing constituted a mistake apparent from the record under section 254(2) of the Income-tax Act. The earlier determination addressed comparability but omitted the distinct recharacterisation issue. Rectification was therefore available, and the Assessing Officer was directed to examine the documentary evidence and determine whether the services fall within the scope of knowledge process outsourcing.

Rectification jurisdiction permits recall of an appellate order where objections challenging revision proceedings remain unaddressed, including reliance on jurisdictional authority and a contention regarding upload of the revision notice. Recall in its entirety is warranted to ensure justice and fair play when the earlier appellate determination omits these material objections. The recall operates in favour of the assessee.

Pending revision applications require expeditious determination where prolonged inaction continues. A revision application pending since March 2016 must be decided in accordance with law within two months after production of the certified order, with the assessee afforded an opportunity of hearing. The direction concerns timely disposal of the revision proceeding and does not determine the merits of the underlying tax claim.

Technology-enabled tax administration supported commercial tax and net GST collection growth in Andhra Pradesh during August 2026 and the cumulative period through August. AI-based analytics and scrutiny, IGST reversals, UPI-based enforcement, registration verification, Aadhaar authentication, digital payment enablement, predictive analytics and data sharing strengthened compliance, scrutiny and revenue mobilisation. Petroleum VAT, professional tax, liquor VAT and IGST settlement also increased, while GST rate reductions moderated net GST performance in specified product sectors.

Section 168A of the Arunachal Pradesh Goods and Services Tax Act, 2017 extends the limitation period for issuing orders under section 73(9) concerning tax unpaid or short paid, or input tax credit wrongly availed or utilised. Orders may be issued until 31 December 2023 for financial year 2017-18, 31 March 2024 for financial year 2018-19, and 30 June 2024 for financial year 2019-20.

Tax officers may use artificial intelligence for abstract research and drafting assistance only where no identifiable taxpayer information or case-specific facts are disclosed. Uploading or transmitting taxpayer records to unauthorised external platforms is prohibited and remains the personal responsibility of the officer, including where a subordinate acts on the officer's behalf. Quasi-judicial notices and orders must reflect the signing officer's independent application of mind, with all AI-generated legal propositions and citations verified from primary sources. Departmental data must not be integrated with external systems or processed through personal devices or accounts.

Automated issuance of Free Sale and Commerce Certificates is enabled on the DGFT portal for eligible exporter applications concerning items outside the Drugs & Cosmetics Act, 1940. The system-driven, risk-based workflow replaces routine manual verification and approval by Regional Authorities, supporting paperless processing and faster turnaround. Applications that require verification or do not meet automated processing parameters will continue to undergo manual processing. Auto-approved applications may also be flagged subsequently for Regional Authority review under the system's risk-management parameters.

Special additional excise duty and road and infrastructure cess on petroleum-product exports are revised with effect from 1 September 2026. The export duty on diesel is increased, the levy on aviation turbine fuel is marginally reduced, and a duty is imposed on petrol exports. Existing duty rates for petrol and diesel cleared for domestic consumption remain unchanged. The windfall-tax framework seeks to support domestic fuel availability and deter exporters from benefiting from domestic and international price differences.