Exhaustion of alternative remedies requires a party challenging an interim protective order to first seek its vacation or modification before the issuing forum. Direct appellate recourse is therefore premature where that remedy has not been pursued. Status quo relief may continue during a winding-up petition where disputes over share transfers and ownership require preservation of the subject matter pending adjudication. Placing idle funds in an interest-bearing fixed deposit may likewise protect the parties' interests while the underlying petition is determined expeditiously.

Rule 87A(4)(c) permits recovery of Registrar of Companies' costs arising from an application or appeal for restoration of a company's name, unless otherwise directed. Because such costs have penal consequences, the amount must bear a rational relationship to actual costs incurred and be supported by a recorded computation or determination. Prolonged non-filing of financial statements, annual returns and income-tax returns remains a serious statutory default that cannot be excused by ignorance or oversight. However, an unsupported quantified restoration cost was found disproportionate and reduced.

Section 125 of the Customs Act does not permit conditional redemption requiring re-export. Accordingly, prohibited goods that cannot be cleared for home consumption and are allowed only for re-export should not attract redemption fine. An admitted misdeclaration supports penalty under Section 112(a)(i), although the value of the offending goods and denial of redemption may justify a reduced penalty. Section 114AA applies to false or incorrect information furnished in any business transaction and is not limited to fraudulent export transactions; penalty may therefore arise on that basis.

Approval of a resolution plan under the Insolvency and Bankruptcy Code, 2016 governs the corporate debtor's claims and liabilities. Once the NCLT approves the plan, a customs demand or recovery cannot be sustained against the corporate debtor. The approved plan accordingly has binding effect on customs claims and precludes post-approval recovery.

Section 80P(2)(d) deduction for interest received by a co-operative housing society from investments with a co-operative bank remains available for the relevant assessment years despite belated returns. During that period, the timely-return condition for Chapter VI-A deductions did not cover section 80P; a processing adjustment denying the deduction solely for late filing was therefore a mistake apparent from the record and capable of rectification. A co-operative bank holding an RBI licence remains a co-operative society registered under applicable co-operative societies law. Its exclusion from claiming its own deduction does not prevent the investing society from claiming deduction on interest received from it.

Statutory limitation under Sections 153 and 144C governs completion of the entire assessment process using the dispute-resolution-panel mechanism. The non-obstante clause in Section 144C(13) requires prompt issuance of a final order after panel directions but does not override the outer time limit in Section 153; harmonious construction preserves both requirements. Pendency of an identical limitation question before a higher court does not itself justify deferral where binding precedent remains unstayed. Section 158AB provides the Revenue's statutory procedure for matters involving identical pending questions of law.

Conditional non-pressing of reopening grounds, expressly linked to relief on other grounds, does not amount to unconditional abandonment where liberty remains to raise factual and legal issues in a departmental appeal. Treating such withdrawal as unconditional, without adjudicating the reserved reopening challenge or considering submissions before issuing directions, may constitute a mistake apparent from the record rectifiable under Section 254(2) of the Income-tax Act, 1961. The appellate order was recalled for de novo adjudication, preserving the assessee's right to raise the reserved grounds.

Section 40A(3) applies only to amounts otherwise deductible in computing business income. Cash payments for land acquisition that are capitalised as a capital asset or purchase advance, rather than claimed through the profit and loss account, do not reduce taxable business profits and fall outside its disallowance mechanism. The curative amendment introducing a tolerance band for stamp-duty valuation differences applies retrospectively. Consequently, a valuation difference within the prescribed 10% limit does not support an addition.

Reassessment following a completed scrutiny assessment cannot rely on a loan transaction already verified merely by revisiting the same material. Recorded reasons must accurately identify the assessee's actual transaction and be supported by transaction-specific fresh tangible material; a mistaken creditor cannot later be substituted during remand because reopening reasons cannot be supplemented or improved. Where these requirements are absent, reopening amounts to a change of opinion, and the related unexplained-credit addition cannot stand.

Delayed filing of Form No. 10AB for regularisation of provisional registration under section 12AB may be condoned where the Commissioner is satisfied that reasonable cause exists under the first proviso to section 12A(1)(ac). Lack of awareness of revised procedural requirements and administrative oversight may constitute bona fide reasons where no benefit resulted from delay. The available statutory discretion, filing extensions, and principles of substantial justice support condonation. Regular-registration applications should then receive fresh consideration, including consideration of the amended memorandum of association.

Reassessment jurisdiction requires the income identified in the recorded reasons for reopening to be assessed; Explanation 3 to Section 147 does not permit unrelated additions where that foundational escapement is not assessed. Such additions are without jurisdiction and must be deleted. Separately, an assessment issued in the name of an amalgamating company after it has ceased to exist is invalid, even if the successor participates. Notice of amalgamation prevents jurisdiction from being sustained through participation or estoppel. Reassessment and consequential additions founded on these defects are legally unsustainable.

Liberal interpretation of sufficient cause favours condoning appeal delays caused by genuine personal hardship and inability to access electronic communications, rather than treating such delay as deliberate or negligent. Additional evidence on joint property ownership, timing of payments and investment sources may be admitted where it goes to the root of a source-of-investment issue. Rule 29 requires the Revenue to receive a fair opportunity to verify that material; the issue must then undergo fresh fact-based determination, with the prior appellate determination vacated where necessary.

Search assessments under sections 153A/153C remained valid because seized documents had an indirect connection with the additions, despite the challenge concerning incriminating material in unabated years. Additions for unexplained bank deposits were not sustainable where fund-flow records and documented sources, including withdrawals, salary, savings, transfers and maturity or sale proceeds, explained the deposits, including joint-account credits. Rough seized salary calculations could not establish undisclosed income without evidence of actual receipt or independent corroboration. A mobile-phone note concerning gold did not prove unexplained jewellery investment absent purchase evidence or a financial trail, particularly where family holdings were within reasonable CBDT norms. Additions based on deposits or informal notings require adequate evidentiary support.

Transferable tenancy rights linked to an identified immovable property and sold for ascertainable consideration constitute a chargeable capital asset for capital-gains purposes. Sections 45 and 48 operate as an integrated charging and computation framework; inability to prove the previous owner's historical acquisition cost following inheritance affects quantification, not chargeability, where the rights remain identifiable and capable of valuation. Fair market value as on 1 April 2001 and the resulting indexed cost require factual and, where necessary, technical verification of the valuation report. Capital gains therefore remain chargeable, subject to lawful recomputation of the taxable amount after valuation and indexation are determined.

BSNL VRS-2019 compensation is treated as retrenchment compensation arising from forced retirement under the BSNL revival scheme, rather than as a payment governed by the voluntary-retirement exemption. The distinction between retrenchment compensation and voluntary-retirement compensation determines the applicable exemption: the payment qualifies for exemption under Section 10(10B) of the Income-tax Act, 1961, as a capital receipt, while Section 10(10C) does not apply.

Reassessment jurisdiction under the amended regime requires information suggesting income escapement and approved satisfaction linking seized material to the assessee; an independent enquiry is not required at that stage. Extended limitation cannot be based on gross alleged unrecorded purchases when only the embedded profit is chargeable, the annual threshold is unmet, and separate years cannot be aggregated. Third-party digital tally data cannot constitute entries in the assessee's books, while undisclosed purchases are not an asset for extended reopening. A belated return filed under Section 148 without extension does not require a Section 143(2) notice. Additions resting on untested third-party statements or records fail where requested cross-examination is denied and corroborative evidence is absent.

Section 153C jurisdiction over a person other than the searched person depends on the deemed search date, determined by recording satisfaction or receiving records. Where satisfaction was recorded in the deemed search year 2022-23, section 153C(3) did not permit proceedings for that year; any reassessment recourse lay under section 147. Jurisdiction also requires a satisfaction note identifying material specifically relating to that person and linking it to alleged escaped income for the relevant assessment years. General references to electronic evidence, or a ledger already contained in regular books without that linkage, cannot support consolidated satisfaction for multiple years. Failure of both requirements renders the assessments legally unsustainable.

Foreign tax credit under Section 90 cannot be denied solely because Form 67 was furnished after the prescribed time. Rule 128(9) requires Form 67 to support a foreign tax credit claim, but delayed filing is a procedural defect that does not extinguish the substantive entitlement. The Assessing Officer must verify the foreign taxes paid and the credit claimed, and allow the credit in accordance with law where the claim is otherwise valid.

Section 10(26AAB) exempts income of an agricultural-produce market committee or board constituted under law to regulate agricultural-produce marketing. A mistaken exemption claim under Section 10(23C) in the return does not defeat entitlement to the correct statutory exemption where the entity's status and prior eligibility are undisputed. Failure to file a revised return should not, in these circumstances, bar the claim under Section 10(26AAB). The exemption remains available subject to verification that the committee or board satisfies the statutory conditions.

Reassessment notices and a consequential assessment issued in the name of a transferor company after its amalgamation were unsustainable because the entity had ceased to exist from the appointed date. The appointed date preceded issuance of notices for reassessment and scrutiny assessment, and the tax authorities had been informed of the amalgamation. Proceedings against the erstwhile amalgamated entity were therefore invalid, resulting in quashing of the reassessment notices and consequential assessment.