Income-tax additions for alleged unrecorded coal purchases require independent evidence linking third-party search material to the taxpayer. Where books are not rejected and no abnormality in production, consumption, input-output ratios or recorded sales is established, a net-profit estimate based on suspected outside-the-books trading is speculative and cannot stand. Likewise, alleged under-invoicing of mill-scale sales cannot be established solely through a retracted statement and CCTV footage when the cash is recorded and supported by available cash balances. Additions based on uncorroborated material, retracted statements and presumptive estimations are deleted.

Reasonable cause may preclude penalties for failures to deduct or collect tax where a bona fide belief is objectively supportable. Payment of rent to a Government-owned company may support a genuine understanding that tax deduction is not required, particularly where the recipient has the character of a State instrumentality. Construction scrap generated through labour and materials may be regarded as outside tax-collection requirements where it does not arise from a manufacturing process. On these principles, bona fide beliefs concerning both obligations can constitute reasonable cause and prevent penalty.

Foreign tax credit claimed under Sections 90/90A is not defeated solely because Form No. 67 was filed after the prescribed timeline. Rule 128(9), which requires furnishing the form, operates as a directory procedural requirement where the credit was claimed in the return and the delay does not undermine the substantive entitlement. The credit remains available subject to the Assessing Officer verifying the relevant facts and supporting documents after providing an opportunity of hearing.

Section 11(1)(a) permits charitable trusts to retain the statutory 15% accumulation independently of the specified accumulation regime under section 11(2). Accumulation beyond that limit remains available where Form No. 10 is furnished by the valid extended return-filing deadline under Rule 17 read with section 139(1). Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late when the audit report was available before return processing and the substantive exemption conditions were satisfied. Procedural delay in prescribed filings does not defeat the exemption where the relevant form is timely under an extended deadline or the audit report is available before proceedings conclude.

Repeated cash deposits followed by similar self-withdrawals and redeposits may establish circulation of the same funds, requiring unexplained-money additions to be computed on the net peak credit rather than gross deposits. Opening cash balance, verified net agricultural receipts, and other disclosed income constitute explained sources and must be credited when determining any unexplained peak. Only the residual unexplained amount remains liable to addition. The amended tax-rate provision for unexplained income, effective from 1 April 2017, applies to Assessment Year 2017-18.

Section 194C(6) TDS exemption for small goods-carriage contractors requires a declaration and PAN, with sufficient particulars to establish eligibility where inquiries reveal discrepancies. Freight-payment and vehicle-registration details may be material in that assessment, but non-verification by the deductor or departure from the Circular No. 19/2015 format alone does not defeat the exemption. Identified declaration defects must be put to the deductor for explanation or cure. Under the first proviso to Section 201(1), physical Form 26A certificates must be examined to verify whether payees reported the freight income and discharged the related tax. Default status and consequential interest require determination after applying these standards.

Interest on bank overdraft funds advanced for a proposed business land acquisition may retain revenue character where the acquisition is abandoned and the advance is refunded before any asset comes into existence. The deductibility of such expenditure is at least legally supportable and debatable; disallowance in quantum assessment alone does not establish concealment of income or furnishing inaccurate particulars. Accordingly, a revenue-expenditure claim of this nature, when not outrightly unsustainable, does not justify concealment penalty under Section 271(1)(c).

Closing stock must be valued at cost or market value, whichever is lower. A stated net realisable value requires supporting material showing its basis; where the taxpayer's rate is unsupported and the assessing officer's market-realisation rate is below cost, the issue concerns the correct realisable-value rate rather than a change in valuation method. Consistent use of a net realisable value method does not protect an unsubstantiated valuation rate. Concurrent factual findings on valuation disclosed no substantial question of law, and the addition for undervaluation of closing stock was sustained.

Purchase additions and wage disallowances cannot rest on suspicion or unsupported presumptions when ledger accounts, invoices, supplier details, bank statements and crossed-cheque payments remain unrebutted. Supplier confirmations alone are not indispensable where no inquiry disproves the purchase records, banking entries or underlying transactions. Likewise, wage expenditure cannot be disallowed merely on an assumption that registers were prepared later or wages were inflated; contrary material and reasons are required. The purchase addition and wage disallowance were therefore treated as unsustainable, restoring the corresponding deletions.

Revisionary jurisdiction under Section 263 cannot be invoked merely because the revisional authority considers enquiries into seized material inadequate after the Assessing Officer has conducted them and adopted a plausible view. Detailed notices, confrontation with seized documents and statements, and consideration of the assessee's explanations demonstrate that the assessment was not made without enquiry. Section 263 applies where lack of enquiry makes an assessment both erroneous and prejudicial to Revenue; it does not permit substitution of the revisional authority's view for a considered assessment decision. The proposed revision was therefore unsustainable.

Reassessment initiated in the name of a deceased assessee does not comply with the statutory mechanism requiring assessment through the legal representative and is invalid. Sale proceeds from land deposited in a bank account may remain an asset for the extended reassessment period because the inclusive definition covers immovable property and bank deposits, where alleged escaped income crosses the prescribed threshold. However, a co-owner's valuation report alone cannot support reassessment: the Assessing Officer must independently examine the assessee's property, undertake appropriate valuation inquiry, consider tangible material, and form a belief that income escaped assessment. Proceedings founded solely on an unverified co-owner valuation are impermissible.

Reassessment notices alleging fictitious or accommodation transactions must disclose sufficient material particulars and the relied-upon incriminating material that prima facie links the assessee to the alleged income escapement. Transaction screenshots identifying values and entities, without the underlying dissemination reports, do not provide an effective opportunity to respond under the statutory pre-notice procedure. The Assessing Officer must meaningfully consider the assessee's documentary explanation and identify material supporting the alleged role in the transactions. Disclosure of relied-upon reports only during writ proceedings cannot cure the initial denial of a meaningful statutory opportunity. Reassessment proceedings initiated without such disclosure are invalid.

Agreements concerning jointly held ancestral land did not establish a transfer of the assessee's capital asset for long-term capital-gains purposes. The land covered by the joint development arrangement was allotted to other family members under the subsequent agreement and final partition decree, while the assessee retained land allotted to his own share. The factual finding of no transfer was supported by the record and was not perverse; deletion of the long-term capital-gains additions was therefore sustained.

Section 179(1) imposes personal liability for unrecovered tax dues only on directors of a private company where non-recovery is attributable to their gross neglect, misfeasance or breach of duty. An incorporated unlisted public company does not become a private company merely because shareholding is concentrated or its shares were not publicly offered. Corporate veil principles require exceptional circumstances, such as use of the company to siphon income or create undisclosed assets, before extending liability beyond the statutory scope. Authorities must consider a director's explanation, record a reasoned causal link between the director's conduct and non-recovery, and disclose adverse material to preserve natural justice.

Input tax credit reflected under the IGST head in GSTR-2A cannot be retained as CGST and SGST credit claimed in GSTR-3B merely on an asserted technical or clerical error. Where the available records show a tax-head mismatch, IGST credit supported by GSTR-2A may be allowed only to that extent, while unsupported CGST and SGST credit remains liable to reversal. In the absence of new facts or records to displace the mismatch finding, reversal of CGST and SGST credit, along with consequential interest and penalty, applies.

Form GST DRC-01 is a summary accompanying, not substituting, the statutory show cause notice required for tax-demand adjudication. A valid notice must identify allegations, statutory contraventions and factual grounds, and provide a meaningful opportunity to defend; issuing a summary with a notice addressed to another taxpayer does not meet those requirements. Input tax credit cannot be denied solely because credit claimed in Form GSTR-3B is absent from Form GSTR-2A for periods before the relevant restriction. Invoice-level details and fulfilment of applicable credit conditions, including receipt of supplies, require verification before disallowance. Demands lacking a valid notice or prescribed credit verification have no legal foundation.

Retrospective GST registration cancellation requires prior disclosure of that proposed action in the show cause notice. Cancellation effective from 27 October 2023 was invalid because the notice did not mention retrospective cancellation, despite the applicable Division Bench ruling and undisputed facts. The cancellation order and show cause notice were quashed, while fresh proceedings in accordance with law remained available.

Input tax credit for February and March 2020 cannot be denied solely for delayed return filing where the returns were filed before the 30 November 2021 cut-off under Section 16(5). Returns filed on 6 November 2020 and 14 November 2020 fall within the extended statutory period, making a denial based on the time restriction in Section 16(4) inconsistent with that benefit. Eligibility for input tax credit remains subject to satisfaction of other applicable requirements.

School affiliation is a statutory and regulatory institutional arrangement rather than a supply of services for consideration. Affiliation conditions applicable to schools are treated as pari materia with those governing colleges affiliated with universities. Affiliation-related services also fall within the educational-services exemption under Entry 66 of Notification No. 12/2017-CT (Rate), including Entries 66(a) and 66(b)(iv). GST on school affiliation fees is therefore unsustainable, rendering the related circular, notice and consequential proceedings untenable.

Section 16(5) confers a substantive entitlement to seek input tax credit without prescribing a period for filing a rectification application. Executive circulars imposing a six-month filing period operate only as directory guidance and cannot override or curtail that statutory entitlement. Rejection solely because the rectification application was filed after the circular-based period cannot stand. Article 226 may permit an extension of time in an appropriate case, unless the delay is exceptional, while the jurisdictional authority must determine the rectification claim on its merits.