Bail on parity with similarly placed co-accused was sought after their release and the petitioner's prolonged custody. The petitioner was alleged to have played a significant role in a fraudulent input tax credit scheme, and documents and electronic records had been seized. The investigation had been completed when an earlier bail application was rejected. Bail was granted subject to a bond, sureties and conditions, while the criminal proceedings remained pending.

Pre-arrest bail concerning alleged dishonoured cheques and monetary transactions remains undecided. The assessment involves the volume and pattern of account transactions, the absence of clear disclosure of their nature and source, and the petitioner's past record. The observations on those matters are prima facie. Tax authorities are to furnish information, and the District Court is to pass a fresh bail order.

Revision under section 263 requires an assessment to be both erroneous and prejudicial to the interests of the revenue. Where the assessing officer has made specific and follow-up inquiries into unsecured loans and considered lender creditworthiness, bank records and repayment, disagreement over the extent of inquiry or a permissible assessment view does not by itself justify revision. Without valid revisional jurisdiction, the assessment remains undisturbed.

Reopening an assessment previously scrutinised under section 143(3) beyond four years requires a failure to disclose material facts fully and truly, as well as a reason to believe that income escaped assessment supported by material. An investigation report and general statement that do not identify the taxpayer or substantiate accommodation entries do not supply that material. Approval based on a mistaken assumption that no prior scrutiny occurred and reliance on the wrong statutory clause do not cure these deficiencies.

Sanction by the prescribed authority under section 151 of the Income-tax Act, 1961 is required for reopening an assessment under sections 147 and 148. Approval granted mechanically, without demonstrating application of mind, is invalid. An endorsement stating "yes, I am satisfied" without showing due application of mind does not constitute valid sanction, making the reopening invalid.

Gross profit-based disallowance of purchases treated as accommodation entries was restricted from 12.5% to 7.5% in favour of the assessee. The assessment treated the remaining purchase value as genuine, so the corresponding business activity could not be doubted in second appellate proceedings on that basis. The reduced disallowance does not serve as a precedent for other assessment years.

Section 153D of the Income-tax Act, 1961 requires prior approval for assessments made by an officer below the rank of Joint Commissioner, covering the preceding assessment years under Section 153A and the search year identified in Section 153B. Approval is not a mere formality: approval dated on the assessment date but communicated to the assessing officer only after completion of the assessment does not satisfy the prior approval requirement. The resulting search-year assessment is void from inception.

Employees' provident fund and insurance contributions are treated as deemed income held in trust and are deductible only if deposited by the applicable statutory due date. Late contributions are disallowable even where return processing preceded the Supreme Court's clarification or contrary High Court decisions previously existed, because the Supreme Court's interpretation applies from inception. The monthly deposit deadline is the fifteenth of the following month, with the five-day grace period applicable to the contributions concerned; it does not depend on when salaries or wages are paid.

Interconnect service charges received by a non-resident telecom operator are not taxable as royalty in India under Section 9 of the Income-tax Act, 1961, or Article 12 of the India-Malaysia tax treaty. The royalty treatment of such receipts follows the jurisdictional High Court decision and coordinate-bench decisions addressing identical facts.

Fresh consideration of transfer-pricing adjustments for notional interest on receivables and corporate guarantees is warranted to allow supporting particulars to be furnished. The taxpayer had not made submissions to the transfer-pricing officer or participated in the dispute resolution panel hearing. Those circumstances and the need to permit supporting particulars were relevant in the interest of justice. The merits of both adjustments remain undecided.

Section 269ST restricts specified cash receipts, and section 271DA prescribes a penalty for contravention. Sworn search statements have evidentiary value and cannot be displaced by an unsupported belated change in position. Cash belonging to another person was admitted as received in a sworn statement, while a later claim that it had been sent to the recipient's son for safekeeping and labour payments lacked documentary support.

Unexplained investment additions cannot rest solely on uncorroborated spreadsheets and untested retracted statements where authorship and cash outflow are unverified; the presumption for seized material is rebuttable. Reassessment notices under section 148 must comply with the faceless scheme under section 151A; issue by a jurisdictional officer outside that framework invalidates the notices. Assessment orders require a computer-generated Document Identification Number, subject to specified exceptions and safeguards; a missing or subsequently generated number without compliance renders the orders invalid. Reassessment notices founded on an alleged search are invalid where no search occurred.

Section 153C of the Income-tax Act, 1961 requires jurisdictional satisfaction that seized material bears on the determination of the total income of a person other than the searched person. Identifying seized sale deeds and connecting them to that person does not satisfy this requirement unless their bearing on total income is recorded. Recording satisfaction is not a mechanical exercise, and an assessment is invalid if the required income-related satisfaction is absent.

A reassessment notice dated 31 March 2021 but issued on 1 April 2021 was required, under the amended reassessment provisions and the Supreme Court's transitional directions, to be treated as a preliminary notice under section 148A(b). The procedure also required an order under section 148A(d) and a fresh notice under section 148 within the surviving limitation period. Neither the required treatment nor the order under section 148A(d) followed, and the notice was quashed and the consequential assessment set aside.

Recorded satisfaction under section 153C must establish that seized material relates to the assessee and bears on the determination of the assessee's total income. These requirements apply to seized digital evidence and are necessary for jurisdiction to initiate proceedings and make an assessment. Satisfaction that does not address both matters is insufficient to support the resulting assessment.

The jurisdictional satisfaction note under section 153C must disclose how seized incriminating material bears on the other person's total income for the relevant assessment years. A common note covering multiple years must establish that connection for those years; assessments without the required jurisdictional satisfaction cannot stand, and additions based on invalid assessments cannot survive. Additional legal grounds may be admitted where they go to the root of the matter and require no fresh investigation of facts.

The reassessment notice under section 148 of the Income-tax Act, 1961, for assessment year 2017-18 was time-barred, invalid and without jurisdiction. It was dated 31 March 2021 but served by email on 1 April 2021, as confirmed by the respondent. No notice under section 148A(b) was issued pursuant to the Supreme Court's directions.

Proceedings under section 148A for assessment year 2016-17 were time-barred because the three-year period expired on 31 March 2020 and the alleged escaped income was below the Rs. 50 lakh threshold for the longer period under section 149. Consequential proceedings under section 148 could not be maintained beyond the statutory period. Where the limitation bar deprives the assessing authority of jurisdiction and requires no detailed factual enquiry, the taxpayer need not pursue proceedings before that authority.

Escaped income represented by expenditure relating to an event or occasion may be aggregated across previous years under Section 149(1A) of the Income-tax Act, 1961, where the expenditure spans those years and the prescribed value threshold is met. A reassessment notice may therefore be issued beyond the ordinary limitation period for a year involving alleged escaped income below Rs. 50 lakh where the aggregate for the relevant event exceeds that threshold. Alleged bogus purchases and cash transactions involving the same proprietary concern were treated as expenditure relating to an event, unlike unrelated transactions.

The prospective omission of restrictions on refunds of integrated tax paid on exports, without a saving clause, prevents their enforcement in proceedings that had not attained finality when the omission took effect. Section 6 of the General Clauses Act does not save those pending proceedings, which lapse; transactions past and closed remain unaffected. Orders under challenge are not treated as closed transactions, including where an appeal remained unavailable because the Appellate Tribunal had not been constituted. The assessee is entitled to a refund, and pending or restored refund applications must be processed in accordance with law.