Trade and quantity discounts earned by a dairy resale agent were explained receipts where bank records showed a joint account with the dairy, same-day deposit and withdrawal of sales proceeds by the dairy, and agency income limited to discounts. Treating those discounts as unexplained money and estimating taxable income by allowing only a portion as storage and distribution expenses lacked justification. The estimated addition was deleted.

Transfer-pricing analysis treats enterprises as associated where an overseas entity's business is wholly dependent on regulatory affairs and compliance processes performed by the Indian entity, engaging section 92A(2)(g). The Indian entity remains the tested party where foreign comparable data cannot be readily accessed or verified. Regulatory affairs services cannot be re-characterised as knowledge process outsourcing unless they fall within Rule 10TA(g)'s exhaustive definition. Comparables performing materially different functions fail functional, asset and risk and comparability analysis; the arm's length price requires fresh benchmarking against functionally comparable entities after an opportunity to furnish relevant material.

Penalty for furnishing inaccurate particulars does not arise where capital-gains computation on a slump sale, including treatment of negative net worth, rests on a bona fide and fully disclosed legal claim. Divergent Tribunal interpretations of the relevant provision and admission of a substantial question of law demonstrated that the issue was debatable. Acceptance of a quantum addition, including by not pursuing a ground to avoid further litigation, does not by itself establish concealment or inaccurate particulars. Penalty was therefore not leviable, and its deletion was sustained.

Section 270A distinguishes under-reporting, penalised at 50% of tax on under-reported income, from misreporting, which attracts 200% only where the specified statutory circumstances are proved. Omitted interest income and its detection by the Revenue establish under-reporting but do not automatically establish misreporting; enhanced penalty requires independent evidence of the relevant statutory ingredients. Non-response to electronic notices alone is insufficient for that characterisation. Multiple reassessment, show-cause and penalty-stage notices may satisfy the opportunity-of-hearing requirement where the taxpayer does not use the available opportunities.

Corpus treatment for infrastructure grants may be established through donor resolutions, earmarking, separate fund accounting and use for the specified infrastructure purpose; a separate written direction for each contribution is not necessary. Charitable entities may claim permitted statutory accumulation and, where applicable, accumulation despite delayed filing of the prescribed form when condonation relief applies. Additions for alleged double application require prior notice and an opportunity to respond. Promotion of cricket does not constitute trade, commerce or business without evidence of commercial operations. Depreciation cannot be denied without proof that asset cost was previously claimed as application, while additions for prohibited benefits and enhanced receipts require identified violations and evidentiary support.

Transfer of an income-tax case under Section 127 requires an order by a competent statutory authority, ordinarily following a reasonable hearing and recorded reasons. A work-allocation order by a Joint Commissioner lacking Section 127 transfer power cannot validly transfer jurisdiction to the officer completing the assessment. The assessee's participation in assessment proceedings or failure to object within thirty days does not cure this foundational jurisdictional defect. The resulting assessment is without jurisdiction and non est, and any penalty founded on that assessment cannot survive.

Rectification of an upward transfer-pricing adjustment under section 92CA(4) reduced the adjustment to nil. As the taxpayer's grievance stood resolved through the rectification order, no grounds remained for adjudication. The Assessing Officer was required to give effect to that rectification, ensuring that the assessment reflects the nil adjustment and the corrected transfer-pricing position.

Section 56(2)(x) permits reliance on stamp-duty value but its valuation presumption is rebuttable. Where an agreement to purchase agricultural land pre-dated the provision, subsequent conversion to non-agricultural use at the purchaser's expense could explain the higher stamp-duty value without establishing undisclosed consideration or independent market appreciation. The purchaser's inability to foresee prescribed banking-mode requirements for advance consideration was material. As the consideration related to the original land extent despite Government retention on conversion, the stamp-duty valuation difference did not justify an addition under Section 56(2)(x).

Territorial jurisdiction of a Tribunal Bench is determined by the location of the Assessing Officer who passed the assessment order, not by the assessee's location or the appellate authority's location. Where the assessment order was issued by an Assessing Officer at Chennai, a subsequent appellate order at Mumbai did not confer jurisdiction on the Mumbai Bench. The related cross-objection, arising from the same assessment proceedings, could not be adjudicated there either. The Revenue's appeal and the assessee's cross-objection therefore required consideration by the appropriate Bench, with all merits remaining open.

Section 69A requires proof that the assessee owned money or valuable assets not recorded in its books. Third-party loose papers, digital entries and statements alleging over-invoicing and cash kickbacks, without a search, cash seizure, asset, bank trail or other independent evidence linking unaccounted funds to the assessee, do not establish such ownership or receipt. An allegation that a supplier returned cash to a customer is also inconsistent with treating that cash as unexplained money of the supplier. Reliance on customer officials' statements without cross-examination further weakens the charge. The stated addition was therefore legally unsustainable and deleted.

Valid revised returns replace original returns, requiring a fresh jurisdictional scrutiny notice; assessments based on revised returns without it are void, and participation or curative service provisions cannot remedy its absence. Trademark depreciation cannot be restricted again after the asset enters the opening intangible-asset block, and road-access payments without a proprietary capital asset remain revenue expenditure. Weighted research deduction cannot be denied solely for absent pre-amendment expenditure quantification, but substantive eligibility requires verification. Interest already taxed cannot be taxed again; sufficient own funds negate proportionate borrowing-cost disallowance absent a proven nexus. Exempt-income disallowance requires account-based satisfaction and cannot be mechanically added to book profit.

Alternative statutory remedy does not preclude Article 226 review where an assessment is made without considering relevant facts and law. Payments received by a postgraduate medical student were treated as salary solely on university information, without addressing certificate and governmental material supporting their character as an exempt stipend. Because the stipend-versus-salary characterisation was a vital factual issue, an effective opportunity to submit supporting documents before the Assessing Officer was required. Relegation to the statutory remedy was therefore unsustainable, requiring fresh determination after consideration of the relevant material.

Search-derived incriminating material concerning a person other than the searched person must be assessed through Section 153C, subject to recording and transmission of the required satisfaction. Sections 147/148 apply only where material is independently sourced and cannot substitute for the search-assessment mechanism. The second proviso to Section 149 also barred recourse to Section 148 where the relevant search commenced before 31 March 2021. Consequently, reassessment proceedings initiated under Sections 147/148 on third-party search material, including the notice and order under Section 148A(d), were invalid.

Valuation references under Section 142A cannot be invoked immediately before assessment limitation expires merely to obtain excluded time under Explanation 1(v) to Section 153. Where asset material and explanations are already available, alleged bogus depreciation may be addressed in the assessment itself. A last-minute valuation enquiry into alleged unaccounted cash, without satisfactory explanation for earlier inaction, constitutes a colourable and impermissible use of power to extend limitation and is invalid.

Input tax credit demands must remain confined to the tax heads, amounts and grounds set out in the show-cause notice under Section 75(7). A GSTR-2A and GSTR-3B mismatch warrants scrutiny but does not, without invoice-level and transaction-based verification, establish wrongful availment or supplier non-payment of tax. Section 16(2)(aa) does not apply retrospectively to Financial Year 2019-20, while Rule 36(4) and prescribed verification mechanisms must be applied according to their relevant periods. Interest and penalty depend on a valid tax determination. A speaking order must address reconciliations, evidence, computations and submissions, with reconsideration limited to the existing notice after effective hearing.

Section 54(3)(ii) permits refund of accumulated input tax credit where the tax rate on eligible inputs exceeds that on output supplies. Inputs include both principal goods and ancillary packing materials used to market packaged tea; comparison cannot be confined to bulk tea and packaged tea while excluding higher-taxed packaging inputs. Refund may therefore extend to credit accumulated on eligible packing materials. Circular No. 135/5/2020-GST concerns rate reductions on the same goods over time and does not govern accumulation arising from packing-material taxes. Administrative circulars cannot restrict a statutory refund entitlement beyond its scope.

Section 54(3)(ii) of the CGST Act permits refund of accumulated input tax credit where eligible business inputs are taxed at rates higher than output supplies. Packing materials used for packaged tea fall within the broad definition of inputs and may generate refundable accumulated credit even when bulk and packaged tea attract the same tax rate. Circular No. 135/5/2020-GST applies to accumulation caused by GST rate reductions on the same goods at different times and does not restrict refunds arising from higher-taxed packing materials. Administrative circulars cannot curtail a statutory refund entitlement.

Statutory limitation under the Central Goods and Services Tax Act applies independently to each financial year. A consolidated show-cause notice covering multiple financial years cannot bypass limitation applicable to earlier years, and separate year-wise demands in DRC-01 do not cure the invalidity of a common notice issued without jurisdiction. Where a jurisdictional defect is apparent from the record and requires no factual enquiry, writ jurisdiction under Article 226 remains available despite a statutory appellate remedy. An invalid notice also deprives the consequential adjudication order of legal effect, although fresh proceedings may be initiated in accordance with law.

Fraudulent GST registrations obtained through misuse of innocent persons' PAN and Aadhaar particulars undermine taxpayer protection and cause revenue loss. Proposed safeguards include stronger identity verification, inter-agency data-sharing, physical verification, and risk-based monitoring to detect and prevent such registrations. GST and police authorities received a final opportunity to develop an effective solution, with the matters remaining listed for further hearing.

Expiry of the extended six-month period under Section 67(7) causes a prohibition order over goods to cease automatically. Detention of goods based on an expired prohibition order exceeds the statutory time limit and is unlawful. Where the prescribed maximum period has lapsed, the goods must be released to the assessee rather than remain subject to continued detention or prohibition.