Independent application of mind is required for sanction under Section 151; a bare "Approved" endorsement without examination of material or satisfaction on reopening is mechanically granted and invalid. Reassessment based on cash deposits in jointly held bank accounts also requires recorded reasons establishing a live nexus between the assessee and income escaping assessment. Where the assessee is only the second account holder, no material links the entire deposits to taxable income, and agricultural activity supports the explanation, the reopening lacks jurisdiction. The reassessment and consequential additions are unsustainable.

Statutory refund interest under section 244A(1)(a) applies to refunds arising from advance tax or tax deducted at source, including refunds resulting from an appellate reduction in the applicable tax rate. Section 244A(2) permits exclusion only for a definite, identifiable period causally delayed by the assessee; an incorrect original tax position, failure to revise a return, or pursuit of a sustainable claim does not alone establish attributable delay. Additional interest under section 244A(1A) applies where an appellate refund is granted after the statutory period for giving effect to the appellate order, absent a valid extension, withholding, adjustment, or assessee-caused delay.

Under the cash system of accounting, genuine business expenditure is deductible on actual payment, even where the underlying Work Contract Tax relates to earlier financial years, unless the accounting method is validly rejected under the applicable statutory framework. Acceptance of the books and consistently followed cash method prevents selective application of mercantile principles merely because the liability arose earlier. Interest paid for delayed Work Contract Tax remains deductible where it compensates the State for delayed payment and is not imposed as a penalty for an offence or prohibited conduct. Assessed income requires recomputation after allowing both deductions.

Cash deposits reflected in regularly maintained books require examination of the cash book, purchase and sale registers, bank ledgers and supporting material before they may be treated as unexplained money. An unexplained-money addition is unsustainable where records correlate deposits with recorded cash balances but are neither scrutinised nor found unreliable. Penalty for non-compliance with information notices lacks basis where the assessee subsequently responds, participates in assessment, and those replies support completion of assessment. Scrutiny of the books and relevant evidence remains necessary for fresh factual determination of the cash-deposit issue.

LLPs whose accounts require audit under the Limited Liability Partnership Rules qualify for the extended return-filing due date under Explanation 2(a)(ii) to section 139(1), which covers audits mandated by laws other than the Income-tax Act. This entitlement does not depend on meeting the tax-audit turnover threshold under section 44AB. A return filed within that extended due date permits carry-forward of business loss because section 80 does not apply to a timely return. Treating an LLP as a non-audit case despite audit particulars disclosed in the return constitutes a mistake apparent from the record and may be rectified under section 154.

Registration under section 12AB cannot be refused merely because an investor-protection fund is financed by a stock exchange and its members. Compensation is payable only to eligible investors whose admitted claims remain unpaid following a trading member's default and insufficient assets; defaulting members neither receive payments nor obtain rights in the fund. Securities-market investors constitute a section of the public sharing a common public interest, not a private group of specified persons. Investor protection, awareness and research activities remain consistent with charitable objects where they are not conducted as trade, commerce, business, or services for consideration. The refusal was unsustainable because the activities were genuine, aligned with the stated objects, and outside the proviso to section 2(15).

Section 151(ii) requires reassessment notices issued after three years from the end of the relevant assessment year to receive prior approval from the Principal Chief Commissioner or Chief Commissioner. For assessment year 2016-17, a notice and an order under Section 148A(d) issued in July 2022 were approved by the Principal Commissioner. Even after accounting for the TOLA extension, approval by that authority did not satisfy Section 151(ii). The defect concerned jurisdiction to issue the reassessment notice, rendering the notice invalid and preventing the consequential reassessment proceedings and assessment from surviving.

Profit-margin comparisons alone do not justify an adjustment to profits of an eligible unit under Section 10A(7) read with Section 80IA(10). The provisions require the contemplated arrangement affecting profits; a higher net-profit margin, without evidence of such an arrangement, is insufficient. On that basis, deletion of the profit addition was sustained, with no substantial question of law arising.

Reassessment under Sections 148A and 148 requires verified material directly linking the assessee to alleged escaped income. An undated complaint that was not investigated, unsupported cash-receipt imagery, and data recovered from the phone of an employee of an unrelated entity do not establish that nexus. Statements recorded later that do not support the alleged cash transaction further weaken the basis for reopening. Reassessment founded on such unverified material, surmises and conjectures lacks a valid foundation.

Reassessment following a completed scrutiny assessment cannot be initiated merely from bank-credit information that was already furnished, queried and examined during the original proceedings. Detailed requisitions for bank-account particulars and statements, followed by acceptance of returned income, indicate conscious consideration of cash deposits and related RTGS transactions. Portal information repeating those records does not establish income escaping assessment. A successor Assessing Officer cannot reopen an examined transaction solely on a different view. Recorded reasons must disclose the completed scrutiny assessment, identify previously undisclosed transactions, and support any allegation that full and true disclosure was not made. Without those jurisdictional facts, reassessment and the consequential demand lack legal basis.

Closure of criminal proceedings cannot rest on an assumption that prosecution's purpose is satisfied where assessment and appellate orders have been partly set aside and remitted, leaving tax liability unresolved. Liability determined and discharged only after the closure order does not establish that it had been fully satisfied when closure was ordered. The closure lacked a sustainable basis and requires reconsideration by the Trial Court after taking account of subsequent developments.

A reassessment notice under Section 148 must be validly issued as a jurisdictional precondition to reassessment under Section 147. Section 159 permits proceedings to continue against legal representatives only when proceedings were initiated during the deceased assessee's lifetime; it does not cure or validate proceedings initiated by a notice addressed to a person already deceased. Where the legal heir objects to jurisdiction without participating in the proceedings, a notice issued after the assessee's death cannot be treated as a notice to that heir. The notice and any direction treating it as issued to the legal heir are void from inception and without jurisdiction.

Unsigned appeal memoranda are a curable procedural defect and should not ordinarily prevent adjudication of underlying tax disputes on merits. The High Court found that, although the assessee had failed to rectify the notified defect and was expected to exercise greater diligence, refusing restoration would make the Tribunal's default dismissals final without merits review. The Tribunal appeals were therefore restored, subject to payment of costs and rectification of the defects within the stipulated period, and were directed to be decided on merits.

Documented long-term gains from listed-share sales through recognised stock exchanges, supported by securities transaction tax, demat records and banking channels, cannot be treated as unexplained cash credits merely because of unusual price movements or concerns about intermediaries. The human-probabilities test remains evidentiary and does not replace positive, corroborated proof linking the taxpayer to unaccounted cash, operators or price manipulation; the gains retain capital-gain exemption. Where the underlying additions fail for lack of such evidence, related concealment penalties lack a basis. Reopening or reassessment founded solely on assessment findings that do not survive also cannot stand.

Validity of reassessment reopening under sections 147 and 151 was raised where approval or sanction of the competent authority was alleged to be absent or granted by the wrong authority. The scope of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA) and the relevance of issuance of notice within four years were also in issue. The Supreme Court dismissed the special leave petition because the special leave petition against the relied-upon judgment had already been dismissed.

Section 197 applications seeking a nil-rate withholding certificate for domain name registration charges under the India-USA DTAA must be decided on their merits, with due regard to treaty obligations rather than revenue targets. The Supreme Court declined to interfere with the High Court's ruling and dismissed the Special Leave Petition, leaving that ruling in force.

Kar Vivad Samadhan Scheme settlement scope concerns the conclusiveness of settlement and the bar on reopening a settled income-tax demand. The Supreme Court dismissed the Special Leave Petition, finding no reason to interfere with the High Court's order. The available material does not specify the High Court's reasoning or the precise legal effect of the order beyond the dismissal of the challenge.

GST exemption for services relating to admission or conduct of examinations is construed strictly and does not extend to affiliation, affiliation-processing, annual registration, or late-registration functions that are antecedent or administrative. Such fees are treated as taxable supplies. Circular No. 234/28/2024-GST confines "as is where is" regularisation to affiliation services and does not cover registration-related charges. Where GST was not separately collected, gross receipts require cum-tax valuation under Rule 35. Extended limitation under Section 74 requires proof of fraud, wilful misstatement, or deliberate suppression intended to evade tax; non-payment and a bona fide view on taxability are insufficient. Interest and penalties apply only to surviving, recomputed tax liabilities, not to time-barred or regularised demands.

Traceable e-wallet credits of quantified GST rate-reduction benefits satisfy Section 171 where they are unconditional, unrestricted, non-expiring, carry monetary value, and are linked to identified recipients and invoices. Automated labelling as "Offers and cashback" does not displace the substance of transaction-specific evidence establishing that the benefit reached eligible customers. Valid credits and accepted credit notes discharge the anti-profiteering obligation to the extent substantiated. An unreconciled residual not linked to any customer or invoice remains unpaid and must be deposited in the Consumer Welfare Fund with applicable interest. No penalty applies for the period preceding the penal provision.

Under the anti-profiteering framework, additional input tax credit must ordinarily be passed on through commensurate price reductions. Verified escalation in major construction-input costs may be considered where it demonstrably offsets that tax benefit. Where accepted additional construction expenditure exceeds the saving from additional input tax credit, the net savings are negative; deducting the cost escalation from the input tax credit saving is therefore appropriate. No profiteering arises in those circumstances, and there is no contravention of the pass-through requirement.