GST audit powers under section 65 of the CGST Act are considered in relation to requests for complete ERP or Tally backups. The issue is whether an audit demand may extend to the entire accounting software backup or should be confined to audit-relevant sales, purchase, input tax credit, ledger and stock records in readable formats such as PDF or Excel. Clarification is also sought on precedent, circulars or departmental instructions concerning such requests.

The rupee appreciated against the US dollar, supported by domestic growth, controlled fiscal slippage, portfolio-related inflows and possible Reserve Bank of India intervention. Its gains were limited by weak equity markets, rising crude oil prices and a stronger dollar. External geopolitical tensions and hawkish US monetary signals remained potential pressures. Domestic indicators showed strong economic activity, while the current account deficit widened because of a higher merchandise trade deficit. Foreign portfolio inflows continued despite investors remaining net sellers during the year.

India's current account deficit widened in the first quarter of 2026-27 as the merchandise trade deficit increased. Higher net services receipts, increased personal transfer receipts and lower net primary-income outgo partly supported the external account. Financial-account movements included higher net foreign direct investment inflows, a shift in foreign portfolio investment from net inflow to net outflow, and lower net inflows through non-resident deposits and external commercial borrowings. Foreign exchange reserves declined on a balance-of-payments basis during the quarter.

Section 106 of the Bharatiya Nagarik Suraksha Sanhita, 2023 permits seizure for evidentiary purposes, while attachment or freezing to secure alleged proceeds of crime falls under Section 107 and requires a competent Magistrate's order and prescribed safeguards. Debit-freezing accounts of persons who are neither accused nor suspected, without material establishing complicity or recorded and communicated reasons, is arbitrary. Such blanket or disproportionate restrictions may impair the constitutional rights to livelihood and to carry on trade or business. The affected accounts were required to be defreezed, subject to lawful action based on positive and specific material under the prescribed procedure.

Section 100 confines second-appellate review to substantial questions of law, while permitting interference with factual findings founded on inadmissible material, disregard of material evidence, misconstruction of documents, or perversity. Reliance on an unproved photocopy to infer authority to alienate property raises a legal question because it is not legally admissible evidence. A notarised photocopy cannot establish a power of attorney unless the original's existence and execution, a recognised basis for non-production, and the copy's authenticity are proved before secondary evidence is admitted. Without that foundation, no presumption of due execution applies and conveyances based on the alleged authority do not bind the affected party.

Under the Prevention of Money Laundering Act, statutory appeals against attachment-confirmation orders must ordinarily be pursued before invoking writ jurisdiction, unless compelling exceptional circumstances establish that the remedy is ineffective or inadequate. The statutory definition of proceeds of crime includes the value of tainted property, permitting proportionate attachment of other property of near or equivalent value when tainted assets are untraceable, unreachable or insufficient. Legitimately acquired and pre-offence property may therefore be attached as equivalent-value property, subject to tentative valuation, periodic review, proportionality, and ultimate confiscation limited to illicit gains.

Deduction under Section 80JJAA may be considered as a fresh appellate claim even where it was omitted from the return of income and Form 10DA was not filed with that return. Non-compliance with those procedural requirements alone does not resolve entitlement. The Assessing Officer must verify whether the substantive statutory conditions are fulfilled and allow the deduction if eligibility is established.

Reassessment initiated more than four years after an assessment under Section 143(3) requires the recorded reasons to establish the assessee's failure to make a full and true disclosure of all material facts necessary for assessment. Where the recorded reasons contain no such allegation, the statutory jurisdictional condition under the first proviso to Section 147 is not met. The reasons must independently demonstrate this condition and cannot be supplemented or improved later. Reassessment proceedings commenced without this recorded allegation are invalid and liable to be quashed.

Reassessment jurisdiction for assessment year 2012-13 required sanction under Section 151 only from the Principal Commissioner. Obtaining additional satisfaction from the Additional/Joint Commissioner alongside the Principal Commissioner did not follow the prescribed jurisdictional procedure. Where a statute requires a jurisdiction-conferring act to be performed in a specified manner, it must be performed only in that manner. The invalid sanction vitiated jurisdiction under Section 147, resulting in the reassessment order being quashed.

Agricultural land recorded in revenue records, situated beyond municipal limits and generating agricultural income in earlier years falls outside the definition of a capital asset when transferred. A later enquiry and absence of cultivation during the transfer year do not by themselves alter its agricultural character. Subsequent conversion to non-agricultural use by the purchaser is immaterial because the land's character at the time of transfer governs. Accordingly, the transfer does not give rise to taxable capital gains.

Alleged suppression of turnover based on a discrepancy between declared turnover and departmental Insight portal data requires verification against the relevant departmental records where the portal figures are substantially consistent with the financial statements and return. The turnover addition was therefore remanded to the Assessing Officer for fresh examination after giving the assessee an opportunity to be heard. GST late fees were treated as allowable business expenditure rather than disallowable penal payments, and the related disallowance was deleted. The central distinction is between a turnover discrepancy requiring factual reconciliation and a statutory late fee deductible in computing business income.

Reassessment based merely on Investigation Wing information and unverified third-party statements lacks the required independent application of mind; after four years, it additionally requires a demonstrated failure of full and true disclosure. Documentary evidence establishing identity, creditworthiness and genuineness of share capital and loans shifts the burden to the Revenue, so unrebutted credits cannot be treated as unexplained and related interest cannot be disallowed. Reduction of previously recognised but unrealised revenue does not itself establish suppression; however, treatment as bad debt requires verification against statutory conditions. The reassessment and cash-credit additions were quashed, while the bad-debt claim required reconsideration.

Recorded cash on hand in the cash book and audited accounts explained demonetisation-period banknote deposits where the Assessing Officer identified no defect in the cash book or dispute regarding the recorded balance. Delayed or staggered deposit of part of the cash, including after an earlier accepted deposit, did not by itself undermine the documented source. The deposits therefore could not be treated as unexplained money.

Revenue expenditure incurred for business remains deductible under section 37 where the tax authorities reject a claim for capital scientific-research expenditure under section 35(1)(iv) but characterise the expenditure as revenue in nature. The disallowance of that expenditure was therefore to be deleted, subject to satisfaction of section 37 requirements. Customs-duty reimbursement claimed for an amount paid by a third party requires factual verification of the payment and reimbursement; that issue was remitted for fresh verification.

Penalty for concealment of income or furnishing inaccurate particulars cannot be sustained where the statutory notice retains both alternative charges without identifying the precise allegation. Effective opportunity to respond requires a notice that clearly specifies the applicable limb. Where penalty initiation proceeds on concealment of income but the penalty is imposed for furnishing inaccurate particulars, the inconsistency further invalidates the penalty. Consequently, penalty under Section 271(1)(c) is not leviable when the notice is vague and the charge adopted at imposition differs from that initiated.

Cash-credit additions for deposits and funds received from relatives cannot be sustained where documentary evidence establishes the source of funds. Sale proceeds of gold ornaments, confirmations from NRI relatives, and their bank statements supported the credits. Material placed on record cannot be rejected without further enquiry from the donors; an assessee cannot be prejudiced by the Assessing Officer's failure to verify that evidence. The Section 68 addition was therefore deleted.

Section 41(1) requires remission or cessation of an existing trading liability; a finding that creditors are non-genuine does not by itself establish that an outstanding liability has ceased. Non-genuineness may instead concern the allowability of expenditure linked to the underlying transactions. Where outstanding creditor balances are subsequently discharged through banking channels, that payment negates an inference of cessation during the relevant assessment year. Additions treating such balances as income on alleged cessation of liability are therefore unsustainable and liable to be deleted.

For reassessment following a return filed in response to a notice under Section 148, issuance of a notice under Section 143(2) is a prerequisite to a valid assessment. Section 292BB cures defects involving service, delayed service, or improper service of a notice where the assessee participates in proceedings, but does not cure complete non-issuance. Accordingly, an assessee's participation without objection cannot validate reassessment proceedings where no notice under Section 143(2) was issued, rendering the reassessment invalid.

Unexplained bank-deposit additions require fresh verification where buyers' receipts and evidence of tea-garden cultivation have not been adequately examined. The Assessing Officer must determine whether deposits represent tea-sale receipts rather than unexplained money. Claims for exemption under section 10(26) and treatment of income as agricultural income also require verification of the taxpayer's qualifying status, the link between buyers' receipts and deposits, and the character and taxability of the income. Fresh adjudication must follow an adequate opportunity of hearing; the appellate order and assessment issues are restored for fact-based reconsideration.

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.