Penalty proceedings under Section 271D for contravention of Section 269SS require the Assessing Officer to record satisfaction concerning the alleged breach during assessment proceedings. Where an assessment completed under Section 144 contains neither such satisfaction nor initiation of penalty proceedings, the jurisdictional basis for the penalty is absent. The resulting penalty proceedings are invalid, requiring deletion of the penalty for want of valid assumption of jurisdiction.

Business-income estimation for a vegetable-market commission agency must reflect activity-specific expenses, including loading, unloading, salaries and administration, after receipts are accepted as turnover. Net-profit results from the immediately succeeding assessment year and comparable taxpayers may guide the rate but are not mechanically determinative. Incomplete records and substantial transaction volume support a reasonable estimated profit. Applying these factors, income is estimated at 2% of total receipts rather than 4%, with consequential recomputation.

Section 14A disallowance for Assessment Year 2018-19 does not arise where no exempt income was earned. The Finance Act 2022 Explanation extending the provision to years without exempt income applies prospectively from Assessment Year 2022-23. For an outstanding sundry creditor liability, production of books, ledger extracts, payment particulars and contemporaneous supporting records discharges the taxpayer's primary burden. A creditor's non-response to a notice seeking information, without evidence that the transaction was fictitious or the liability nongenuine, does not justify adding the entire balance; restricting the addition where verification remains incomplete is treated as reasonable.

Penalty for concealment or furnishing inaccurate particulars does not arise merely because a statutory-tax liability is disallowed under Section 43B where the liability was recorded through the balance sheet, not claimed as profit-and-loss expenditure, and fully disclosed in the tax-audit report. A plausible legal claim and complete disclosure distinguish a quantum disallowance from penal conduct. Similarly, foreign dividend income disclosed in Schedule SI at the applicable special rate, but omitted from the summary computation through a reporting mismatch, does not support penalty where rectification was voluntarily sought before revisionary proceedings and there was no deliberate suppression or tax evasion.

The beneficial tolerance provision in the third proviso to Section 50C is treated as retrospectively applicable, requiring adoption of the declared sale consideration and preventing an addition where the DVO valuation exceeds it by no more than 10%. Bona fide pursuit of rectification proceedings before the appellate authority, followed by prompt filing after rejection, constitutes reasonable cause for a 60-day filing delay.

Royalty payments inseparably linked to manufacturing and benchmarked under an aggregated TNMM approach should not be separately tested or recast as a cost contribution arrangement without a material change in facts; the related transfer-pricing adjustment is removed. Engineering and design comparables require functional similarity and reliable segmental data; a diversified entity lacking reliable segmental information and affected by an extraordinary acquisition should be excluded, requiring recomputation of the margin. Expenditure attributable to exempt income may be disallowed under Section 14A and amended Rule 8D once the Assessing Officer records dissatisfaction with the taxpayer's claim; the disallowance is sustained where personnel costs were omitted.

Reassessment beyond three years requires recorded reasons and approval linking escaped income exceeding the threshold to an identified asset, qualifying expenditure, event or book entry under section 149(1)(b); unaccounted receipts or payments alone do not meet that jurisdictional condition. For a pre-search assessment year, an assessment under section 143(3) without recourse to sections 147 and 148 lacks the prescribed statutory basis. Electronic material, including WhatsApp chats and cash books, must be authenticated and corroborated through source extraction, chain of custody, transaction context and year-specific evidence. Retracted statements, unexplained figures and unreconciled cash-book entries cannot, without independent corroboration, establish unaccounted sales or support net-profit estimation.

Payment under the Direct Tax Vivad se Vishwas Scheme satisfies section 5(2) where a revised Form-3 imposes a deadline that had expired before its issue, but the declarant pays the determined amount within fifteen days of receiving the certificate and submits Form-4. A deadline incapable of literal compliance cannot support a demand or interest for non-compliance. Upon valid payment and intimation, the designated authority must record payment and issue Form-5.

Reassessment requires income to have escaped assessment. Where a company validly adopted a 15-month first financial year under the Companies Act, 2013, and disclosed the entire income for that period in its assessment-year return, including the income targeted in reassessment proceedings, no income remained undisclosed or escaped. Reassessment is therefore impermissible where the proposed addition concerns income already returned for the valid first financial year.

Limitation for a notice under Section 153C depended on the six-year look-back period applicable where alleged escaped income was below Rs. 50 lakh. Because the satisfaction note was recorded in assessment year 2023-24, the period reached back only to assessment year 2017-18. Assessment year 2016-17 therefore fell outside the prescribed period, rendering the notice time-barred in favour of the assessee.

Section 153A read with Section 153C permits a ten-year assessment period only where escaped income exceeds the prescribed threshold. Where the satisfaction note was recorded in assessment year 2024-25, the backward computation reached only assessment year 2015-16. Notice issued for assessment year 2010-11 was therefore beyond limitation, time-barred and invalid.

Materially identical reassessment challenges require adherence to the coordinate bench approach, while disputed allegations of a spurious transaction and escaped income remain matters for factual examination by the Assessing Officer. For assessment year 2020-21, the reassessment order and consequential notice were not considered fit for writ interference because the underlying information and allegations had already been addressed for the preceding year. Judicial discipline supported following the prior approach in the assessee's own matter.

Reopening of assessment under section 149(1)(b) raised questions on the jurisdictional effect of a prima facie opinion under section 148A, including whether it bars a roving inquiry, and on whether cash withdrawals are an "asset" within section 149. The Supreme Court dismissed the oral-hearing application and the review petitions.

Maintainability of a special leave petition turned on an unexplained 468-day filing delay after the High Court dismissed the underlying appeal because of low tax effect. The delayed filing lacked a satisfactory explanation. The petition was therefore not entertained and was dismissed on the ground of delay, without reconsidering the low-tax-effect basis on which the underlying appeal had been dismissed.

Departmental appeals before GSTAT must comply with Board-prescribed monetary limits under the CGST Act. Circular No. 207/1/2024-GST sets a monetary threshold for such appeals and permits exceptions only for specified excluded categories. A recurring or interpretative issue does not alone justify an appeal below that limit; the exception requires a genuine recurring question or wider, substantial revenue impact consistent with the policy of reducing unnecessary litigation. A penalty-only appeal below the threshold is therefore not maintainable where no recurring issue, cascading effect, or substantial revenue implication is established.

For periods preceding 10 July 2024, crediting money to the Electronic Cash Ledger constituted a deposit, not payment of an identified GST return liability. Sections 39, 49 and 50 and the payment rules required debit of the appropriate ledger to discharge the liability; interest on the cash component therefore continued until debit. The later proviso to Rule 88B(1), excluding amounts credited and continuously available before the due date from interest, operates prospectively rather than declaratorily. Notice defects do not invalidate proceedings without demonstrated prejudice, and failure to provide a requested hearing need not result in remand where the record is complete and no additional defence exists. Amounts paid or recovered require demand-wise reconciliation to avoid double recovery.

GST registration cancelled solely for continuous non-filing of returns may be set aside where no tax-evasion process is alleged. Continued cancellation prevents invoice issuance and business operations, which can hinder tax recovery, while pending returns are required to determine final tax liability. Restoration is conditional on filing returns for the entire default period and paying the required tax, interest, fine and penalty within four weeks; on compliance, the jurisdictional officer must restore the registration.

Section 16(2)(c) of the CGST Act remains a valid condition for input tax credit, and a recipient's bona fide conduct does not override a supplier's failure to discharge tax liability. Section 74 demands, however, require disclosed transaction-specific material and reasoned findings that wrongly availed or utilised credit resulted from fraud, wilful misstatement, or suppression of facts with intent to evade tax. General assertions based on retrospective cancellation of supplier registrations, without supplier identities, invoice details, cancellation particulars, credit attribution, or supporting material, do not establish the statutory prerequisites or permit an effective response.

Input tax credit remains conditional on the supplier's payment of tax; the constitutional challenge to that condition and the request to read it down were rejected. A demand based on retrospective cancellation of supplier registrations must, however, establish the statutory elements of fraud, wilful misstatement or suppression to evade tax. General audit objections without supplier-wise invoices, cancellation dates, attributable credit, supporting material, or findings on the taxpayer's defence of genuine transactions and contemporaneous registrations do not provide the required factual and statutory foundation. The demand and consequential proceedings were set aside and remanded for fresh adjudication after notice and an effective hearing, without deciding the merits.

GST registration cancelled solely for non-filing of returns may be restored conditionally, since continued cancellation prevents invoicing and business operations and may hinder tax recovery. Restoration requires filing all pending returns and paying applicable tax, interest, fine and penalty within the stipulated period. Compliance enables restoration and permits final determination of tax liability through filed returns; non-compliance results in cancellation continuing.