GST refund claims subject to a deficiency memo in FORM GST RFD-03 must, pending portal functionality, be rectified and resubmitted under the original ARN. Re-credit of input tax credit to the electronic credit ledger through FORM GST RFD-01B is not required, and jurisdictional tax authorities must accept the rectified claim under that ARN. Separate treatment is contemplated where re-credit has already occurred.

Section 8 of the Court Fees Act, 1870 requires ad valorem court fee on land-acquisition compensation appeals, calculated on the difference between the amount awarded and the amount claimed by the appellant. Additional compensation, solatium and statutory interest are mandatory, inseparable components of the composite compensation award. As the Reference Court's award is a deemed decree, an appeal seeking reduction or exclusion of any quantified statutory component seeks modification of that decree. Section 8 contains no exemption for appeals confined to statutory additions; fixed court fee is therefore insufficient.

Redemption of mutual fund units acquired through surplus-fund investments for liquidity management is distinct from trading in goods or providing an exempted service. Accordingly, the common-input-service reversal or payment mechanism under Rule 6(3)(i) of the Cenvat Credit Rules, 2004 does not apply. Notice-pay compensation recovered from employees leaving without completing their stipulated notice period compensates premature departure; it is not consideration for agreeing to tolerate an act or situation and is not a declared service under Section 66E(e) of the Finance Act, 1994. No service-tax liability arises from either activity.

Mechanical, combined and non-speaking statutory approval without demonstrated application of mind fails the mandatory safeguard for search assessments, rendering the affected assessments void. Depreciation on a non-compete fee remains allowable within a block of assets when accepted in an earlier year and no changed circumstances exist. Rental receipts from property first let during the relevant year are taxable as Income from House Property, with the applicable statutory deduction. Exempt-income expenditure cannot be disallowed through the prescribed mechanism unless dissatisfaction with the taxpayer's accounts is recorded. An additional legal ground challenging assessment validity is admissible where all necessary facts already appear on record.

The Finance Act, 2022 amendment to section 14A operates prospectively and does not govern assessment years 2017-18 and 2020-21. Rule 8D computation requires the Assessing Officer to record, after examining the accounts, dissatisfaction with the correctness of the taxpayer's own disallowance; general observations on investments, mixed funds, or administrative expenses do not meet that condition. A notional section 14A disallowance cannot be added to book profit under section 115JB merely through clause (f) of Explanation 1, which is confined to specified amounts debited to the profit and loss account. The additional disallowance and corresponding book-profit adjustment are unsustainable.

Cash-deposit addition in an income-tax assessment required consideration of the taxpayer's explanation that deposits arose from prior withdrawals and past savings. The explanation was partially substantiated, and an allowance for past savings was considered warranted. The addition was consequently restricted to the supported extent, while the remaining balance was deleted in full.

Section 69B unexplained-investment additions cannot rest solely on an estimated construction valuation where the recorded investment appears in books of account that have not been rejected and no material establishes actual excess cash investment. In those circumstances, reliance on a valuation reference for making the addition is impermissible. Self-supervision allowance in construction valuation must be computed on the gross valuation rather than only on the differential amount. These principles limit valuation-based additions to situations supported by evidence beyond estimation.

Penalty under Section 271C was not sustainable where a materially incorrect loss disclosure could plausibly be attributed to clerical error. The substantial difference between the disclosed and actual losses supported that possibility, rather than establishing a basis for penalty. The penalty was therefore deleted in favour of the assessee on the stated facts.

Statutorily mandated contributions earmarked for accumulation, with only the interest available for welfare objects, have the capital character required for corpus treatment. Restrictions preventing use of the principal for the trust's objects provide the specific direction necessary to treat the receipts as corpus. Such contributions are not assessable as income. Further, Section 12(1) covers voluntary contributions; if the contributions are non-voluntary, they independently fall outside that provision's scope. The resulting addition is deleted.

Income surrendered during a survey for unrecorded loans to debtors and excess cash, when entered in the regular books before the return is filed and offered to tax, remains business income where it arises from the taxpayer's grain, oilseed and pulses trading activities. In the absence of material showing an independent source of income, the unexplained investment and money provisions do not apply. Consequently, the special tax rate for such unexplained income is inapplicable, and the disclosed additional income is taxable at normal business-income rates.

Alleged bogus purchases and unrecorded sales receipts require fresh verification where the taxpayer seeks to substantiate reconciliations and supporting material. The admitted bogus input-tax-credit claim does not remove the need to examine explanations concerning purchases, sales receipts, and documents placed on record. Fresh consideration by the Assessing Officer is required after providing a reasonable opportunity of hearing, so that the reconciliation and supporting evidence can be properly evaluated.

Higher-rate taxation under Section 115BBE requires establishing that income voluntarily declared in a search-assessment return is unexplained or undisclosed income. A declaration alone, without incriminating material or a separate addition, does not satisfy that requirement where the income is stated to arise from regular business. In those circumstances, the declared income is assessable at the regular tax rate rather than the higher rate under Section 115BBE.

Section 153D requires prior approval for each assessee and each assessment year after examination of the relevant draft assessment order and material. A single consolidated approval for multiple assessees and assessment years, without discernible separate consideration, does not satisfy that requirement and demonstrates lack of independent application of mind. Approval is not an administrative formality; a mechanically granted consolidated approval is invalid, vitiates the assumption of jurisdiction, and renders the resulting assessment orders liable to be quashed.

Transfer-pricing benchmarking under the transactional net margin method requires economically and functionally comparable entities. Material turnover differences can affect market position, bargaining power, economies of scale, brand advantage, capacity for complex contracts and profitability; high-turnover and functionally dissimilar entities should therefore be excluded when benchmarking captive software development services. Interest on overdue associated-enterprise receivables must reflect the actual credit risk. Where no basis supports a higher spread and the holding-company receivable presents limited credit risk, LIBOR plus 200 basis points is an appropriate benchmark. The arm's-length price requires recomputation on these bases.

CSR-related donations disallowed as business expenditure under Explanation 2 to section 37(1) may nevertheless qualify independently for deduction under section 80G, provided its conditions are met. Adding back the CSR outlay under section 37(1) prevents double deduction, while mandatory CSR spending does not prevent a payment from being treated as a donation where no quid pro quo exists. Revisionary jurisdiction under section 263 requires both demonstrable error and prejudice to the Revenue. It is not available merely because another view is possible where the assessment record shows enquiry into donation receipts, supporting evidence, payment mode and computation, and the deduction is legally sustainable.

For assessment years beginning before 1 April 2021, the first proviso to section 149(1)(b) permits a notice under the new reassessment regime only if reassessment remained within the erstwhile limitation period when the notice was issued. The extended limitation period under the new regime cannot revive a reassessment power already time-barred. For Assessment Year 2016-17, the former six-year period expired before the June 2024 notice, rendering it time-barred and legally invalid.

Proper officers should accept complete GST registration cancellation applications within 30 days, except where mandatory particulars are missing or a successor entity in a transfer, merger or amalgamation is unregistered. Cancellation takes effect from the date sought, but not before the application date. Applicants must receive written discrepancy details, seven working days to respond, and an opportunity of hearing before rejection. Cancellation does not discharge existing liabilities, and the final return remains mandatory. Closing-stock tax liability may be discharged with the final return, with any shortfall paid in cash.

Refund claim for Assessment Year 1999-2000 must be considered by the assessing authority after the petitioner furnishes the revised return and indemnity bond. The petitioner may submit those details, and the assessing authority must hear the petitioner before deciding the refund claim. The matter was listed for a further date.

Clause (i) of Explanation 1 to section 115JB requires a provision for diminution in the value of an asset to be added back to net profit for book-profit computation. The Schedule VI definition of "provision" covers amounts written off or retained for asset diminution; therefore, a provision for doubtful debts remains such a provision even when shown as a reduction from sundry debtors on the asset side of the balance sheet. Principles governing an actual write-off for ordinary deduction purposes do not apply to this distinct computation. Failure to examine the required add-back may render an assessment erroneous and prejudicial to Revenue, permitting revision under section 263.

Reassessment under sections 147 and 148 requires tangible material with a live link to income escaping assessment in the relevant year. Findings from subsequent assessment years cannot be mechanically applied where the relevant year lacked global-deal agreements, related revenue transfers, and the Hyderabad unit. Material discovered during an ongoing assessment for a later year was distinguishable. Recorded reasons founded on later-year facts amounted to a reason to suspect rather than a reason to believe; the reassessment and consequential assessment were invalidated.