Prior release of frozen property for failure to file a prosecution complaint within the prescribed period does not decide the merits or bar a subsequent attachment. Orders quashing predicate-offence and money-laundering proceedings for particular individuals do not prevent continuation of proceedings against a firm or adjudication of attachments concerning other individuals. Compensation paid for environmental-clearance and forest-law violations neither compounds money-laundering offences nor offsets proceeds of crime from alleged illegal mining. Bank deposits representing available proceeds of crime, or their equivalent value, remain attached pending finality of the PMLA trial.

Provisional attachment of alleged proceeds of crime represented as long-term capital gains from share sales continued because the share purchasers appeared to have been funded from sources other than their own. Funds were routed through banking channels to acquire shares in non-functioning companies at highly appreciated prices, without an apparent commercial basis for the valuation. The investment explanation was treated as unconvincing, including in light of the appellant's role in the trust operating the university. As the scheduled-offence and money-laundering trials remained pending, the attachment was retained to secure the alleged proceeds of crime until trial conclusion.

Leasehold transfers of land to approved Special Economic Zone units qualify as transfers of land for stamp duty and registration fee exemptions intended to promote industrial establishment. A lease conveys a transferable interest in land for the stipulated term and is not confined to an outright sale. Promissory estoppel protects SEZ fiscal incentives promised under State policy where a lease was executed before the implementing Ordinance, because the Ordinance gave statutory effect to the existing policy. Denial based solely on the timing of the Ordinance would defeat the governmental promise and create unequal treatment of similarly situated SEZ units. The exemption consequently extends to the leasehold transfer, requiring refund processing.

GST reimbursement for ongoing works may cover the net additional burden arising from GST introduced after bidding where tender rates were inclusive only of taxes applicable at that time. Government measures addressing GST impact on continuing contracts support compensation once the additional liability is verified. A pre-bid clarification concerning future taxes cannot supersede inconsistent tender terms. Refusal of verified reimbursement, particularly where similarly placed contractors receive different treatment, raises arbitrariness and equality concerns under Article 14.

Territorial appellate jurisdiction allocated by a CBDT circular to the Commissioner of Income-tax (Appeals)-18, Chennai for Tamil Nadu and Puducherry cases is indispensable to the valid exercise of quasi-judicial authority. An appellate authority not vested with jurisdiction over an assessee's dispute, including an authority at Delhi, cannot validly decide it. Orders issued without the requisite territorial jurisdiction are null and void and liable to be quashed.

Wealth-tax appellate jurisdiction lay with the Commissioner of Income-tax (Appeals)-18, Chennai under the applicable jurisdictional framework. Orders issued by the Commissioner of Income-tax (Appeals)-31, Delhi lacked legal jurisdiction and were therefore invalid. Because the competent appellate authority had not adjudicated the assessee's substantive grounds, the appeals required remand for fresh consideration. The appeals were restored to the Commissioner of Income-tax (Appeals)-18, Chennai for de novo adjudication on merits after hearing the assessee.

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.