Territorial jurisdiction allocated by a CBDT circular is indispensable to an appellate authority's valid exercise of quasi-judicial power. Appeals arising within the Tamil Nadu and Puducherry charge fell within the jurisdiction of the Commissioner of Income-tax (Appeals)-18, Chennai. An appellate authority at Delhi lacked authority over the assessee's dispute; consequently, its appellate orders were without jurisdiction, null and void, and quashed.

Where appellate orders are void for want of territorial jurisdiction, quashing those orders does not dispose of the underlying appeals or grounds challenging wealth-tax additions. The appeals must be restored to the jurisdictionally competent appellate authority for fresh adjudication on merits, with an opportunity of hearing. Failure to direct such restoration constitutes an omission warranting rectification.

Cash refund is available under Section 142(3) of the CGST Act for CVD and SAD paid after 1 July 2017 on de-bonding of capital goods where those duties were eligible for CENVAT credit but could not be carried forward into GST. Section 140(1) permits transition only of eligible credit reflected in the return immediately preceding the appointed day; post-GST duty payments cannot appear as such closing credit. Section 142(3) therefore applies to refund claims under the existing law and requires cash payment, subject to exclusion of credit already transitioned.

Pre-notice payment of service tax and interest on product support services attracted the statutory benefit for such payment, rendering the related penalty unsustainable. Transfer of the right to use software embedded in a product constituted a deemed sale of goods subject to VAT, including customised software, so licence fees were not liable to service tax. Consultancy expenditure did not attract reverse-charge service tax under the Place of Provision of Services Rules, 2012. Remuneration paid to full-time directors for services rendered as employees fell outside the definition of taxable service; reverse-charge liability therefore did not arise.

Separately recovered NSE/BSE transaction charges, SEBI fees, stamp duty, depository/DEMAT charges, bandwidth charges and securities transaction charges do not form part of taxable brokerage or commission where they are collected under statutory or regulatory requirements, not retained by the service provider, and remitted to the relevant authorities or providers. They are reimbursable pass-through expenses rather than consideration for stock-broking, commodity-broking or depository services. Extended limitation cannot apply where service tax was paid on actual charges, returns were regularly filed, and no wilful suppression with intent to evade tax was alleged or established. Tax demands, consequential interest and penalties based on including those charges cannot be sustained.

Extended limitation and penalties for service-tax non-payment require wilful suppression or intent to evade; non-declaration alone is insufficient where services, contractual arrangements and banking-channel consideration are evident. Card-customer sourcing performed by a direct selling agent, without collecting customer payments and for turnover-based commission, falls within business auxiliary service rather than payment-card services before 1 July 2012. Recipient entitlement to input credit does not remove the supplier's liability for tax and interest on its own taxable services during the normal period. Mutual fund agent services covered by reverse charge place tax liability on the service recipient, making a demand on the agent unsustainable for that period.

Corporate amalgamation required substitution of the appellant's name in the service-tax appeal cause title, from the predecessor company to the amalgamated company. Supporting documents were filed to establish the change in corporate identity. The registry was directed to amend the cause title so that the pending proceedings reflect the successor entity's current name.

Indexed cost of improvement in computing capital gains requires supporting evidence of the expenditure. Passage of time does not remove the taxpayer's obligation to substantiate a claimed improvement cost. Where no evidence supports the claim, the indexed cost of improvement is not allowable and is disallowed in computing capital gains.

Interest earned by a primary credit co-operative society on deposits with co-operative, scheduled and nationalised banks qualifies for deduction under sections 80P(2)(a)(i) and 80P(2)(d), where the relevant statutory conditions are met. The treatment applies to interest income arising from deposits held with both co-operative and other banking institutions. Interest received on an income-tax refund is also included within the deduction available under section 80P(2)(c)(ii). The deductions claimed under these respective provisions are consequently available to the society.

Cash deposits arising from the sale of rural agricultural land were satisfactorily explained by registered sale records, the sale agreement, cash received instead of the cheque recorded in the sale deed, and additional sale consideration. As the land was not a capital asset and sale income was exempt, the stated sale proceeds constituted an acceptable source for both deposits. No addition as unexplained money was sustainable where the Revenue did not dispute the land's rural agricultural character or the exempt nature of the sale income.

Government securities held by banks are treated as stock-in-trade, so diminution in their value, when recorded under banking norms, is allowable as revenue expenditure. An additional depreciation claim raised during assessment may be determined from material already on record. Mutual-fund dividend income is exempt where a revised computation and supporting evidence establish its receipt and no factual rebuttal arises. Taxable income is consequently recomputed after allowing the securities depreciation and exempt-dividend claims.

Penalty for concealment under Section 271(1)(c) cannot survive where it is founded on an unexplained cash-deposit addition that has been deleted in quantum proceedings. The penalty attributable to that deleted addition was therefore removed. However, where an interest-income addition remained unchallenged in the quantum appeal, the penalty corresponding to that undisclosed income remained sustainable.

Rectification under Section 154 is unavailable where interest income was declared in the return and accepted in assessment, unless the assessment order itself contains an apparent mistake. An alleged error in the return does not by itself establish a rectifiable error in the assessment. A non-speaking appellate dismissal arising from non-compliance requires fresh, reasoned adjudication where the taxpayer must receive a reasonable opportunity to substantiate the claim that income was inadvertently offered to tax. The substantive taxability claim therefore remains open for appellate consideration on supporting material.

Deduction for an approved industrial park under Section 80IA(4)(iii) remained available because the Central Government's Empowered Committee had not withdrawn its original approval and compliance with the approved conditions was established. Rule 18C places approval and compliance examination with the Central Government; CBDT's role after approval is limited to notifying the industrial park. CBDT therefore lacked statutory authority to retrospectively rescind its notification while the underlying approval continued. The undertaking was entitled to the deduction for the relevant assessment years.

Covid-related delay in filing a first appeal may constitute bona fide and reasonable cause for condonation where the effective delay is not inordinate. For non-compliance with statutory notices, an assessment completed after the assessee furnished an explanation, even if unsatisfactory, indicates participation rather than total non-appearance. In those circumstances, penalties for repeated defaults may be confined to the initial default instead of being imposed separately for each notice, resulting in substantial reduction of the non-compliance penalty.

Cash found at a taxpayer's residence cannot be treated as unexplained money in that taxpayer's hands when evidence establishes ownership by another taxpayer. Cash-balance details and income-tax returns showing sufficient disclosed cash-in-hand of family members independently conducting business supported attribution of the cash to joint-family business proceeds. Co-residence within a joint family did not, by itself, establish that the cash belonged to the taxpayer. On those facts, the unexplained-money addition under Section 69A was unjustified and deleted.

For completed or unabated assessments, additions under section 153A require incriminating material found during the search. Third-party email backups, bank-payment analysis and statements did not independently establish unaccounted sales where no cogent or corroborative evidence was found at the assessee's premises. Post-search compilations did not constitute seized incriminating material, and selective reliance on unsupported statements could not sustain additions for alleged suppressed sales. The additions for the relevant assessment years were therefore deleted.

Peak-credit computation of seized finance-business notebooks treats undisclosed receipts and outgoings as business income where no separate non-business source is established. Section 69 deeming treatment for unexplained investment does not apply to the peak amount in those circumstances. Interest, commission and miscellaneous receipts already included in the peak-credit working cannot be separately added while retaining that computation, because this would tax the same income twice. Where excluding those receipts eliminates the peak credit, undisclosed finance-business receipts remain taxable only through the sustained peak-credit business-income computation.

Section 80P deduction cannot be disallowed solely through a computation sheet where the assessment order, on the same limited-scrutiny issue, expressly records that no addition was made. Although a computation sheet forms part of the integrated assessment process and may determine tax payable, it must be read consistently with the assessment order. Where the order gives no reasons or discussion for rejecting the only Chapter VI-A deduction claimed, a contrary computation-sheet disallowance lacks a discernible basis. The disallowance and consequential demand are therefore unsustainable, and the order sustaining them is set aside.

A standard Deficiency Memo format prescribed in Annexure-I to CBIC Circular No. 31/2026-Customs must be used immediately for every drawback claim processed under Section 74 of the Customs Act, 1962. The requirement addresses the absence of a uniform format and is intended to ensure consistency, transparency and timely disposal of drawback claims. Additional/Joint Commissioners and Deputy/Assistant Commissioners must sensitise officers under their charge and ensure strict compliance with the prescribed format.