Commission receipts may be computed on a presumptive basis where the receipts are accepted but the claimed indirect expenditure is not supported by an agreement, evidence of services, or proof of exclusive linkage to commission activity. Income is consequently computed at 50% of commission receipts under Section 44ADA rather than by disallowing all expenditure. Books of account may be rejected where disclosed sales are materially lower than bank credits and the excess credits remain unexplained; profit estimated at 8% of those credits on a presumptive basis remains sustained.

An omitted Section 80C deduction cannot be obtained through rectification of an intimation where no deduction was claimed in the original return, because neither the Section 143(1) intimation nor the Section 154 rectification order contains a rectifiable error. Where supporting evidence of qualifying investment exists, the taxpayer may seek permission under Section 119(2)(b) to file a revised return and make the deduction claim in accordance with law.

Income surrendered during a survey from excess stock and cash at business premises is assessable as business income at normal rates where it is consistently recorded as business income, has a nexus with regular business stock, and no separate undisclosed asset or non-business source is identified. The enhanced tax rate under Section 115BBE does not apply before its effective assessment year. Disallowance under Section 14A remains sustainable when computed under the statutory mandate, and an ad hoc disallowance of business expenditure may be sustained where reasonable on the facts.

Unaccounted purchases that generate corresponding sales give rise only to the profit embedded in those transactions, rather than their gross value. For reassessment notices issued beyond three years, the Section 149 threshold must be tested against that real escaped income; where embedded profit is below Rs. 50 lakh, extended reassessment is unavailable. Search material relating to an assessee must be assessed through the Section 148 reassessment route rather than directly under Section 143(3). Before 1 April 2023, a 30-day period for filing a return under Section 148 was permissible. A cross-examination objection requires a specific request during assessment proceedings.

Penalty for furnishing inaccurate particulars cannot rest on an addition absent from the assessment order. Interest on enhanced compensation involved a debatable taxability issue subject to divergent judicial views, and mere disallowance of a claim does not, by itself, establish inaccurate particulars. The penalty order also proceeded on an erroneous factual premise. Penalty was therefore unsustainable and deleted in favour of the assessee.

Protection insurance, processing fees and annual maintenance charges linked to genuine bank borrowings used to acquire a let-out property fall within deductible interest under section 24(b). The inclusive definition of interest covers service fees and other charges relating to money borrowed, debt incurred or a credit facility. Where the charges have an undisputed nexus with the borrowing, they are treated as interest for deduction purposes, extending the section 24(b) deduction beyond periodic loan interest.

Deduction for a co-operative society providing credit facilities to members depends on the statutory conditions for Section 80P(2)(a)(i). A society not shown to be a co-operative bank, including through an RBI banking licence or other statutory conditions, is not excluded by Section 80P(4). General allegations of failed mutuality, nominal or non-member dealings, irregularities, or fund diversion cannot deny the deduction without identified year-specific transactions and attributable income. Further factual verification should not permit a roving enquiry where prior proceedings provided opportunity to produce evidence. A protective disallowance unsupported by proven nominal-member dealings does not itself establish failed mutuality.

Section 80GGC permits deduction for non-cash political contributions where the recipient is registered, payment is made through banking channels, and a donation receipt is available. General search material alleging accommodation entries cannot, without assessee-specific evidence of cash repayment and an opportunity to rebut third-party material, justify disallowance. Similarly, an addition for unexplained money under Section 69A requires proof that the assessee received or owned the alleged cash. Statutory presumptions and preponderance of probabilities cannot replace foundational evidence linking the assessee to a cash-back arrangement.

Reassessment initiated against a successor amalgamated entity was not invalid merely because notices and the assessment retained the predecessor's old PAN. Where the recorded reasons correctly identified the successor and its new PAN, and the successor participated without confusion or prejudice, the PAN mismatch was a rectifiable clerical defect under Section 292B. Conversely, reopening based on alleged escaped commission income could not support an unexplained unsecured-loan addition when no addition was made on the recorded reason. Explanation 3 to Section 147 permits assessment of other escaped income but not a new-issue addition after the original reopening ground yields none.

Excess input tax credit proceedings under the CGST Act cannot be sustained where the taxpayer reverses the entire wrongly availed credit and pays applicable interest before issuance of a demand-cum-show-cause notice. Recovery for wrongly availed credit is governed by Section 73, while interest is governed by Section 50. Where revenue records acknowledge complete reversal and payment of interest before proceedings begin, no factual basis remains for a further demand. Consequential interest and penalty are therefore not payable.

GST appellate pre-deposit remains mandatory even where tax was paid during adjudication and only the penalty is disputed. The GST framework provides no exemption from the statutory deposit required to file an appeal. The correctness of tax and penalty liability, including the legal effect of tax paid during adjudication, must be examined on the merits by the appellate authority and cannot support waiver of the pre-deposit requirement. Exemption from statutory pre-deposit is therefore unavailable in these circumstances.

Challenge to a GST demand order in Form GST DRC-07 raised alleged statutory and natural-justice violations. The petitioner was granted liberty to pursue the statutory appellate remedy on making the prescribed pre-deposit and filing an application to condone delay. The appellate authority may assess whether delay should be condoned and, if satisfied, determine the appeal on its merits in accordance with law.

Challenge to a show cause notice and tax demand was raised in a writ petition. The writ petition was disposed of with liberty to pursue the statutory appeal. The statutory appellate route remained available for the petitioner to contest the show cause notice and tax demand through the prescribed appeal process, instead of obtaining substantive relief in the writ petition.

Challenge to a Form GST DRC-07 order alleging illegality, breach of the GST Act and denial of natural justice was disposed of with liberty to pursue the statutory appellate remedy. The petitioner may file an appeal on the prescribed pre-deposit and seek condonation of delay. The appellate authority may consider the delay application and, if satisfied, decide the appeal on merits in accordance with law.

Challenge to an assessment order despite an available appellate remedy was addressed through writ jurisdiction. The writ petition was disposed of with liberty to pursue the statutory appeal, subject to the prescribed pre-deposit and an application for condonation of delay. Coercive recovery under the garnishee notice was stayed for the period permitted to file the appeal.

GST appellate pre-deposit is not required where the disputed tax has already been paid under the IGST regime and the dispute concerns whether supplies are inter-State or intra-State, resulting in CGST and SGST liability. As the demand did not involve excess input tax credit, requiring a further 10% deposit under Section 112 would not be warranted for access to the appellate remedy. An appeal may be filed before the GST Appellate Tribunal within one week without that additional pre-deposit, while all merits issues remain open.

Section 73(2) of the Telangana Goods and Services Tax Act, 2017 governs the limitation period for proceedings concerning financial year 2020-21. A show-cause notice issued on 15 July 2025 and assessment orders passed on 9 September 2025 fell after the applicable cut-off date of 28 February 2025. Proceedings initiated or concluded beyond that limitation period are time-barred, involve a jurisdictional error, and cannot sustain consequential recovery action.

Failure to consider a taxpayer's reply to a show-cause notice and to provide a personal hearing before an adverse GST adjudication breaches the requirement under Section 75(4). Differing dates in the adjudication order and its annexure supported the inference that the reply, filed before the order, was not considered. Availability of an appellate remedy does not bar writ relief where adjudication denies this procedural opportunity. The adjudication and appellate orders were unsustainable, resulting in relief for the taxpayer.

Excess input tax credit confirmed without a reply was quashed where the disputed credit had subsequently been reversed and sufficient credit was available in the electronic credit ledger during the relevant period. The taxpayer must receive a fresh opportunity to file a reply and supporting evidence to substantiate the claim. The matter was remitted for de novo adjudication on merits.

Delay in filing a statutory GST appeal under Section 107 may be condoned where circumstances beyond the assessee's control prevented timely filing and refusal would deny an effective appellate remedy. Portal-only service of an order may not, in appropriate circumstances, justify rejection of the appeal solely on limitation grounds. The appellate authority must entertain and decide the appeal on merits if it is filed within 30 days of upload of the condonation order.