For the purposes of the relevant subsection of section 206 of the Income Tax Act, 2025, Adjudicating Authority has the meaning assigned under section 5(1) of the Insolvency and Bankruptcy Code, 2016. For the purposes of the relevant clause in the Explanation to section 115JB of the Income Tax Act, 1961, the same term has that meaning. Both provisions therefore use the definition from the Insolvency and Bankruptcy Code for their respective purposes.

Discount or interest on deep discount bonds and business debentures is deductible proportionately on accrual for the relevant accounting year, even though payment is due at maturity. The contractual liability arises when the instruments are issued, while the borrowing provides a business benefit over their term. Accrual accounting and the matching principle allocate the expenditure across that period, permitting deduction of the portion attributable to each accounting year.

Documents found during a survey attract a rebuttable presumption under section 292C of the Income-tax Act, 1961 concerning their ownership and the truth of their contents. The assessee bears the burden of rebutting that presumption. A receipt figure matching the accounts can corroborate recorded actual receipts, and an addition for unaccounted receipts may be based on survey evidence rather than solely on a survey statement. An unrebutted presumption concerning the document may support the addition.

Silver mixed with palladium alloy is taxable as silver bullion under the applicable notification. Palladium is costlier than silver, distinguishing the mixture from inferior alloys and supporting its classification as silver bullion for tax purposes. This treatment is in favour of the assessee, and no question of law arises.

Central excise tax effect is approximately Rs. 5 lakh. An existing central excise precedent applies against the Revenue.

Survey statements alone cannot support an addition for suppressed receipts, although independently gathered survey material may be assessed on its merits. Cash purchases of emergency medicines and surgical disposables may qualify for deduction despite exceeding the statutory cash-payment threshold where cash payment is a compulsion of normal practice and the purchaser has no other choice. Maintenance payments forming part of a tenancy arrangement may be taxable in the assessee's hands even if paid to the assessee's father, particularly where claimed maintenance expenditure is unsubstantiated.

Disallowance of a bona fide deduction claim supported by a legitimate basis does not, by itself, justify a penalty for furnishing inaccurate particulars. A managerial service fee deduction claimed in the year corresponding income was received had a legitimate basis where an earlier assessment permitted the expenditure to be claimed in that year and the record supported the claim's bona fides.

Central excise was the subject of a civil appeal in which no ground was found to interfere with the impugned order. The appeal was dismissed.

Section 14A and Rule 8D address expenditure attributable to income excluded from total income. No disallowance under Section 14A can be made where no exempt income is earned during the relevant year. The restriction is intended to prevent a taxpayer from obtaining both exempt income and a deduction for expenditure related to that income.

Disputed diamond purchases may be subject to an estimated addition of 6% for possible revenue leakage where purchase invoices, payment details, stock records and sales records attract no adverse findings, consistent with jurisdictional precedent and treatment of similar accommodation-entry purchases. Information from a third-party investigation into accommodation entries can support a belief that income escaped assessment, particularly where verification of the purchases in the original assessment has not been established, rather than constituting a mere change of opinion. Prior approval under section 153D applies to assessments under section 153A or 153C, not reassessments completed under section 143(3) read with section 147.

Capital gains on land converted into stock-in-trade are taxable proportionately when the converted stock is sold or transferred. Under sections 45(2) and 48 of the Income-tax Act, 1961, the fair market value on the conversion date is used as consideration for computing the gains. Stamp-duty value cannot replace that fair market value. Valuation may be determined through a valuation-cell reference or evidence of contemporaneous registrations, with closing stock recomputed accordingly.

Service tax exemption applies to original works relating to a single residential unit that is not part of a residential complex. Constructing multiple independent houses within the same housing scheme does not, by itself, make them part of a residential complex; houses with independent access and separate utility connections qualify for the exemption. Refund may be claimed by the person who bore the tax incidence. Where work orders require the contractor to bear service tax and the Housing Board deducts its reverse-charge share from payments to the contractor, unjust enrichment does not bar the refund, which carries interest at the applicable rate.

Expenditure disallowance under Section 14A and Rule 8D is limited to the exempt income earned, even when a taxpayer voluntarily offers a higher disallowance. There is no estoppel against law, and assessed income may fall below returned income where an amount was wrongly offered to tax. Accordingly, a voluntary disallowance exceeding exempt dividend income does not prevent the disallowance from being restricted to that income.

Revisional jurisdiction over a block assessment requires the assessment to be both erroneous and prejudicial to revenue. Disagreement with an assessment following adequate inquiry does not by itself establish those conditions. The assessing officer had sought an explanation of seized documents, and the same explanation had been accepted in related group assessments without contradictory material. Variations between earlier disclosures and block returns had also been accepted in those assessments; establishing an error in the relevant disclosure required supporting inquiry and material.

Revision under section 263 requires a block assessment to be both erroneous and prejudicial to revenue. A legally sustainable view reached after inquiry cannot be displaced merely because further inquiry is preferred. An assessment is not erroneous simply because the order does not describe the inquiries and their outcomes. Share investments identified through post-search inquiries unrelated to seized material fall outside the block assessment. An undated, unsigned and unsent letter alleging payments could not be correlated with evidence found during the search, and the related seized entries had been explained during assessment.

GST late-fee recovery under Section 74 is discussed in relation to a delayed GSTR-9 filing for 2017-18. The taxpayer says the portal displayed no late fee when the return was filed because of a technical defect, while fees displayed for other years were paid. The taxpayer sought the benefit of an annual return amnesty scheme, referring to a Kerala High Court judgment, and questioned the basis for invoking Section 74. On appellate pre-deposit, a participant refers to Circular No. 259/05/2026-GST and says no 10% or 20% pre-deposit of late fees is required where tax is not in dispute.

Revision of a block assessment under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. An assessment is not erroneous merely because it lacks detailed discussion of matters investigated by the Assessing Officer. A legally permissible view adopted after inquiry cannot be revised solely because a different view is preferred. Issues considered and decided in appeal merge with the appellate order.

Writ jurisdiction cannot be used to override the statutory limitation for a GST appeal and direct condonation of delay. Section 107 of the Central Goods and Services Tax Act, 2017 prescribes the appeal period, and its limitation mandate binds the exercise of writ jurisdiction. Where Section 5 of the Limitation Act is inapplicable, an appeal remains time-barred if it exceeds the prescribed period even after the relevant exclusion.

Registration of a company whose primary object is said to be assisting member industries, rather than the public at large, remains under consideration. The rejection of its registration application was quashed, and an appeal against that result was admitted for consideration. The appellant was directed to produce the company's constitutional documents. No final adjudication on registration took place.

Corporate guarantees between related parties may constitute taxable supplies without consideration when made in the course or furtherance of business. Taxability must be determined before valuation; Rule 28(2) does not itself create a GST charge. For qualifying guarantees furnished to banks or financial institutions for related recipients in India, the rule generally deems the value to be one per cent of the guaranteed amount per annum or the actual consideration, whichever is higher. Where the recipient is eligible for full input tax credit, the invoiced value is deemed to be the supply's value. Relief granted for particular unremunerated subsidiary guarantees does not invalidate the rule or establish a general exemption.