Government securities held to maturity by a bank are treated as stock-in-trade and may be valued at cost or market value, whichever is lower. Resulting revaluation loss is deductible. Bad debts actually written off in respect of non-rural advances remain deductible despite a provision for bad and doubtful debts relating to rural advances. The proviso to section 36(1)(vii) prevents double deduction for rural advances but does not restrict deductions for actual write-offs of non-rural debts.

Section 72(c) of the Black Money Act creates a conclusive, self-executing fiction: undeclared foreign assets acquired before the Act commenced are deemed acquired in the previous year when a Section 10 notice is issued. Assessment must follow in the immediately succeeding assessment year. Where no declaration was made, Section 72(b) does not apply. A first notice in FY 2018-19 therefore permits assessment only for AY 2019-20, rendering assessment for AY 2018-19 without jurisdiction and invalidating consequential proceedings.

Section 153C proceedings cannot be initiated where the deemed date of search falls after 1 April 2021. Under the proviso to section 153C(1), that date is when the searched person's Assessing Officer records satisfaction and forwards seized material to the assessee's Assessing Officer. Where forwarding occurred after that date, section 153C(3) rendered the provision inapplicable, resulting in quashing of the notice and consequential assessment; other grounds became academic.

Section 270A penalty for misreporting income was deleted where failure to file the original return was unintentional and resulted from severe personal and professional hardship. Salary income had already been subjected to tax deduction at source and was available in departmental records. The assessee disclosed that income in response to reassessment proceedings, and the reassessment accepted the returned income. These facts established reasonable cause and supported immunity from penalty despite non-filing of the original return.

Salary earned by a Vietnam tax resident for employment exercised and services rendered in Vietnam qualifies for exemption in India under Article 16(1) of the India-Vietnam DTAA, read with section 90. Taxability depends on where employment is exercised and services are performed, rather than on the continued use of an Indian payroll, payment into an Indian bank account, or tax deducted at source. On that basis, remuneration for Vietnam-based employment does not accrue or arise in India under the domestic salary-tax provisions, and the claimed treaty exemption applies.

Prospective operation of exemption notifications prevents a later amendment from governing imports where the bills of lading pre-date its commencement, unless the amendment expressly provides otherwise. Imported second-hand digital multifunction print and copying machines therefore could not be denied consideration for provisional release by applying the subsequent amendment retrospectively. Provisional release must be considered under applicable customs law and may be granted subject to lawful conditions and compliance, without affecting the pending adjudication proceedings.

Under the Sabka Vishwas Scheme, timely payment and withdrawal of pending litigation are substantive conditions for a discharge certificate, while notifying the designated committee of withdrawal is procedural. Where payment was made within time and withdrawal was sought while the Scheme operated, delayed court listing during the COVID-19 period cannot defeat relief. Portal closure or delayed proof of withdrawal does not justify refusal of the certificate or revival of the demand. The declaration must be processed manually and the discharge certificate issued once the substantive conditions are met.

DGFT regularisation of EPCG imports after payment of duty and interest rendered confiscation of the imported goods and penalty for non-fulfilment of export obligation unsustainable. The Tribunal allowed relief from confiscation and penalty while leaving the unchallenged duty and interest liability intact. Duty foregone on capital goods imported under an EPCG licence must be computed using the assessable value declared in the Bill of Entry, rather than the value stated in the licence.

GST show cause notices initiate, rather than conclusively determine, tax liability. Statutory adjudication must consider the registered person's reply; recording the reply as unsatisfactory does not preclude independent examination of whether it received adequate consideration. Objections concerning audit findings, limitation, tax computation and treatment of deposits fall for determination by the Adjudicating Authority. Writ intervention should not ordinarily pre-empt that statutory process, and substantive objections remain available during adjudication.

Section 122(1A) of the CGST Act may impose a penalty on any person, including an unregistered or non-taxable person, rather than only a taxable person. It applies only where a specified contravention under Section 122(1) is established and it is independently proved that the person retained the transaction's benefit and that the transaction occurred at that person's instance. As a penal provision, it operates prospectively for underlying acts or transactions occurring from 1 January 2021, rather than by reference to the show-cause notice date. Statutory appeals remain available for fact-specific findings despite writ determination of recurring legal questions.

Hookah service in designated smoking areas is absolutely prohibited: the post-2017 replacement of "no other service" with "no service" bars every form of service, including self-service or purported rental models. Preparing, supplying, operating, or maintaining hookah for consideration remains a service because its use requires apparatus and technical assistance; patrons lack the unrestricted possession and control required for a rental. Food-safety law does not cover tobacco products, and municipal law provides no separate hookah-licensing power. Police may enforce smoking-in-public-place and tobacco-sale restrictions through statutory search, seizure, confiscation, and penalty powers.

Input tax credit on expenses attributable to the fresh issue component of an initial public offering is available where the net proceeds are used in furtherance of the company's business. Services used to raise capital for expansion, capital expenditure, working capital, repayment of borrowings and other business purposes have a substantial nexus with business operations and do not fall within blocked credits. In contrast, credit is unavailable for expenses attributable to an offer for sale by existing shareholders because those proceeds accrue to the shareholders rather than the company.

Reassessment founded on a share transaction wrongly mapped to an assessee's PAN is unsustainable where the underlying information concerns another person. Initiating proceedings without verification merely to avoid limitation constitutes a colourable exercise of reassessment power. The reassessment order and consequential notice were quashed, and costs were awarded in the proceedings.

Separate transfer-pricing adjustment for notional interest on delayed trade receivables from associated enterprises is not warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings, because delayed collection creates no additional financing burden. Debt-free status requires verification from financial statements and other relevant records. If verified, the adjustment for interest on outstanding receivables is deleted. This approach applies across the assessment years concerned.

Third-party search material triggering reopening is governed, under the pre-amendment framework, by the search-assessment mechanism rather than ordinary reassessment. Material handover to the receiving Assessing Officer is treated as the third-party search date for computing the ten-year assessment block; consequently, the notice for AY 2013-14 was time-barred. Extended reassessment limitation also cannot be invoked by aggregating alleged expenditure from separate furniture and interior-work orders unless it relates to the same event or occasion. Distinct orders, payment dates and time periods constituted separate events, making the extended period unavailable. Reassessment notices for AYs 2013-14 and 2014-15 were therefore quashed as barred by limitation.

The search-penalty framework under section 271AAB(1) requires a finding that surrendered income meets the statutory definition of undisclosed income; surrender during search alone is insufficient. The notice and penalty order must specify the applicable statutory default or clause, because an admission in a search statement does not automatically attract the provision. Where the assessment order is appealed, search-penalty proceedings must be completed within six months of receipt of the appellate order; an order issued after that period is barred by limitation.

Transfer-pricing benchmarking must separately assess support services rendered on a cost-plus, limited-risk basis and subcontract receipts from a full-risk entrepreneurial segment where separate agreements, functional profiles and risks apply. Their common character as BPO services does not justify aggregation, particularly where separate audited accounts are furnished. The Tribunal rejected aggregation on those grounds. Applying the jurisdictional High Court ruling, the Tribunal also deleted notional interest on delayed receivables because the assessee was debt-free and the Revenue did not distinguish the precedent. The appeal was allowed.

Additional evidence supporting unexplained creditor balances and sales rebates requires verification before the related tax claims are resolved. Agricultural-income exemption and expenditure claims depend on disclosure of agricultural activity, land particulars, sale evidence, agricultural use, and supporting vouchers. Share application money claimed as refunded requires confirmation whether shares were allotted before any reduction is treated as short-term capital gain. Estimated agricultural expenditure should account for assertions that plantation costs were incurred in earlier years and current expenses were limited to maintenance.

Transfer-pricing tolerance under Rule 10CA(7) can apply where an internal comparable produces a single value, since its arithmetical mean remains that value. Where the variation falls within the notified tolerance, the declared price is treated as arm's length. Corporate-guarantee commission may be determined at 0.5% where identical facts and unchanged circumstances support reliance on an earlier determination. Notional interest on outstanding associated-enterprise receivables depends on verifying a uniform policy of not charging interest to third-party export customers; if substantiated by evidence, no interest adjustment should arise.

Where CBDT pecuniary-jurisdiction instructions allocate an assessee's case to an ITO, a scrutiny notice issued by an ACIT without a prior transfer order is beyond that officer's jurisdiction. An assessment founded on that notice is invalid and may be quashed without examination of the merits. The same jurisdictional principle applies where a reassessment notice is issued by an authority lacking jurisdiction over the assessee. Proper allocation and transfer of jurisdiction are therefore essential to the validity of income-tax assessment proceedings.