Notional interest on outstanding trade receivables from associated enterprises need not attract a separate transfer-pricing adjustment where the taxpayer is completely debt-free. Under the arm's-length framework, delayed recovery does not impose an additional financing burden if the taxpayer has no interest-bearing borrowings and incurs no borrowing cost. The debt-free status for the relevant years must be verified from financial records. If verification confirms complete absence of debt, the notional-interest adjustment on delayed receivables must be deleted.

Section 254 appellate jurisdiction permits the Tribunal to admit a Section 54F deduction claim not made in the reassessment return or before the Assessing Officer; the revised-return restriction applies to the Assessing Officer, not the Tribunal. A reasonable explanation supported admission because the assessee had initially disputed taxability of the capital gain and had not raised the alternative deduction claim. As factual eligibility and statutory conditions had not been examined, the Section 54F claim was remitted for verification of supporting evidence and adjudication in accordance with law.

Compensation received by BSNL employees under the 2019 Voluntary Retirement Scheme is treated as qualifying retrenchment compensation eligible for exemption under Section 10(10B). Where an employee originally sought relief under Section 10(10C), appellate jurisdiction can consider the exemption under the correct provision even without a revised return. The bar on fresh claims made otherwise than through a revised return is confined to the Assessing Officer and does not prevent an appellate authority from granting a substantively available exemption. Eligibility must therefore be assessed under the applicable provision rather than rejected for an incorrect original claim.

Section 69A requires reliable proof that the assessee owned or received the precise sum in the relevant previous year and that its nature and source remained unexplained. The cheque advance received during property-transfer negotiations had an identified payer, banking trail and established character, so it was not unexplained money; any retained advance required consideration under section 51 in the relevant year. The alleged cash consideration lacked proof of delivery or receipt, while the agreement, broker statements and electronic communications were inconsistent or uncorroborated. The cash amount was therefore not assessable as unexplained money. Both additions were deleted.

Reassessment notice issued under Section 148 in the name of a person who died before its issue is invalid unless the legal representative submits to the Assessing Officer's jurisdiction without objection. Intimating the Revenue of the death or registering the legal representative on the income-tax portal does not constitute such submission. Recognition of the heir without issuing a notice in that person's capacity does not cure the defect. Section 159 permits lawful proceedings against legal representatives but does not validate a notice addressed to a deceased person; the notice was quashed.

Trusts with both charitable and religious objects are eligible for registration under Section 12AA. Section 11(1)(a) covers income from property held wholly for charitable or religious purposes, while Section 12AA does not distinguish between charitable trusts, religious trusts, and trusts with mixed charitable and religious objects. Mixed objects therefore do not disqualify a trust from obtaining registration, provided the trust otherwise satisfies the applicable registration requirements.

Rubber contraceptives manufactured by an eligible industrial undertaking fall outside the Eleventh Schedule exclusions relevant to crown corks and pilfer-proof caps. Those entries apply only to the specifically identified products and cannot be expanded to cover all goods made of rubber. Deduction under Section 80IB therefore remains available for rubber contraceptives. Consistent acceptance of the deduction on identical facts in other eligible years also supports uniform application of the provision.

Section 72(c) treats a foreign asset acquired before commencement of the Act, where no Section 59 declaration was made, as acquired in the financial year in which the first Section 10 notice is issued. This statutory fiction operates by reference to the previous year, requiring assessment in the immediately succeeding assessment year. Where the first notice issued in Financial Year 2018-19, deemed acquisition falls in that year and is assessable only for Assessment Year 2019-20; an assessment for Assessment Year 2018-19 lacks jurisdiction.

Commission payments subject to withholding obligations under section 195 cannot be disallowed under section 40(a)(ia) where applicable precedent does not require such withholding. Sections 10A and 10B operate as special, self-contained regimes for eligible export undertakings. Amounts recovered from employees and liabilities written back constitute business income where they arise incidentally from activities integral to the export business and are undertaken on commercial expediency. Such receipts form part of the undertaking's profits rather than being separately assessable as income from other sources under section 56.

Transfer-pricing comparable selection is a factual, data-driven exercise governed by Rule 10B and ordinarily permits interference only where findings are contrary to law or perverse. Functional dissimilarity justified excluding two companies from the arm's length price analysis. As no material established factual error or perversity in the comparability findings, the exclusion was sustained and the substantial questions of law were resolved for the assessee.

Reassessment proceedings founded solely on alleged share-sale information cannot be sustained where the information was incorrectly mapped to the taxpayer's PAN and actually concerned another person. A notice and order initiated without verifying the taxpayer's particulars, particularly merely to meet a limitation deadline, lack a valid factual basis. Reliance on admittedly incorrect third-party information constitutes a colourable exercise of power, rendering the reassessment action legally unsustainable.

Pending Supreme Court proceedings concerning a settlement plan required the Department to establish its tax claim within those proceedings. The claim had not been extinguished, compromised, or adjudicated through the settlement process, while asset attachment and deposit of sale proceeds protected the Department's interests. Consequently, the admitted substantial questions in the tax appeals remained unanswered, and the appeals were disposed of with liberty to seek revival if necessary.

Government securities held by banks, including securities retained to maturity, constitute stock-in-trade. Such securities must be valued at cost or market value, whichever is lower, so any diminution on revaluation is allowable. Actual bad-debt write-offs concerning non-rural advances are separately deductible and need not be reduced by a provision for bad and doubtful debts relating to rural advances. The restriction on write-off deductions prevents double deduction only for rural advances, preserving full deductions for non-rural bad debts.

Condonation of delay requires a timely application supported by a satisfactory explanation establishing sufficient cause. An appeal filed after prolonged delay, without a condonation application, may be treated as time-barred and defective, particularly where repeated opportunities to cure defects remain unused. A plea of lack of notice or ex parte disposal does not establish sufficient cause where directors filed adjournment applications and contemporaneous records show knowledge of the proceedings. On these facts, refusal to condone delay and dismissal of the appeal as time-barred and defective were justified.

Assessment for Financial Year 2021-22 cannot rest on cash-deposit and fund-transfer entries recorded in Financial Year 2022-23 unless their relevance to the assessment year is properly determined. Credits dated 4 to 21 May 2022 were identified in the revision record as pertaining to Assessment Year 2022-23. Failure to address the objection concerning this temporal mismatch in revision undermines the validity of the addition and revisional action, as the objection goes to the root of the assessment.

Section 144C draft-assessment procedure is addressed in relation to Dispute Resolution Panel jurisdiction, changes of forum, and the validity consequences of issuing a final assessment order without a draft order. The discussion also distinguishes section 144B from section 144C and considers assessment-completion limitation under section 153, the impact of remand on limitation, and courts' capacity to direct fresh assessments.

Validity of reassessment proceedings was challenged on limitation grounds. The Special Leave Petition was filed after an 840-day delay that remained unsatisfactorily explained. No good ground existed to interfere with the High Court's order. The key legal points concern the limitation applicable to reassessment challenges and the requirement to satisfactorily explain substantial delay when seeking appellate intervention.

Input tax credit on services attributable to the fresh issue component of an initial public offering is available where the net proceeds are used in the course or furtherance of business. Business furtherance includes activities supporting, facilitating, promoting or advancing business, including capital raising for expansion, working capital, repayment of borrowings and general corporate purposes. Such fresh-issue expenses are not treated as blocked credits. Credit attributable to an offer for sale by existing shareholders is unavailable because the sale proceeds do not accrue to the company and the related expenditure is not incurred in furtherance of its business.

Vehicle-registration mismatch in an e-way bill raises whether a completely incorrect number is substantive non-compliance attracting a detention penalty or a bona fide clerical error. One view treats a total mismatch as beyond concessions for minor errors and supports an unrebutted presumption of intent to evade tax. The opposing view treats it as typographical where invoices and other particulars of the goods are genuine and no material establishes mens rea. The difference has been referred for nomination of another member; no final determination on the penalty has occurred.

E-invoicing requirements apply to notified registered persons, requiring an invoice with IRN/QR code before goods commence movement. Failure to generate the e-invoice at that stage is a procedural lapse, but a transit penalty is not justified where the tax invoice, e-way bill and lorry receipt accurately identify the parties, goods, value and tax liability. Where no discrepancy, concealment, falsification, undervaluation or intent to evade tax is established and the later e-invoice corresponds to the same transaction, the penal consequence under Section 129 is unsustainable.