Section 69 applies to investments made during the relevant financial year whose nature and source are not satisfactorily explained. The tax authority must first establish the investments made during that year and their amount; the taxpayer must then explain their nature and source. A year-end asset disclosure may reflect cumulative holdings, including earlier investments. An addition cannot be sustained solely on that disclosure without determining the investments made during the year and examining admitted evidence of investment movements. The investments and their nature and source require fresh determination.

The difference between the valuation and purchase consideration of a co-owner's share was excluded from taxable income based on similar treatment for co-owners of the same property and reliance on a coordinate-bench decision. The deletion also reflected the particular facts and the small amount involved and did not establish a proposition of general application.

For assessment year 2019-20, a section 80P deduction could not be disallowed for late filing through a return-processing adjustment under section 143(1)(a)(v), although section 80AC imposed a due-date condition. The Finance Act, 2021 later expanded the adjustment provision to cover deductions under the relevant heading of Chapter VI-A. Eligible interest from investments or deposits with co-operative banks qualifies for deduction under section 80P(2)(d), subject to verification: the exclusion of co-operative banks from claiming the deduction does not prevent their treatment as co-operative societies. An otherwise admissible deduction cannot be denied solely because disclosed income was entered in the wrong return column, subject to verification of its source.

Article 13 of the India-UK tax treaty requires technical or consultancy services of the kind in issue to make technical knowledge or skills available for the recipient's independent use; managerial services fall outside the definition of fees for technical services. IT, shared information, group support, regional and other support charges are not taxable as fees for technical services where there is no evidence that the recipient can independently perform the services using transferred knowledge or skills. Charges for centrally procured standard third-party software supplied to group entities at cost also fall outside that category where the arrangement provides no technical, managerial or consultancy services and makes no technical knowledge, expertise or processes available.

Penalty under section 271G for failure to furnish transfer pricing information is not sustainable where the taxpayer substantially complies with prescribed requirements and unavailable third-party information falls outside those obligations. The penalty applies to documents or information prescribed under Rule 10D and requisitioned under section 92D. Furnishing the valuation report, transfer pricing documentation and other available material may constitute substantial compliance. Additional information may be sought directly from the third party or valuer. Acceptance of the valuation in quantum proceedings further undermines the alleged basis for non-furnishing.

Transfer pricing characterisation and comparability depend on the actual functions performed, assets employed and risks assumed by the relevant business segment. Ancillary dry blending to customer-provided formulations, without substantial product transformation, does not by itself justify treating an entire distribution business as manufacturing or applying manufacturing comparables to it. Accounting classifications and machinery alone do not determine the functional profile. The functions and risks of a separate marketing support services segment cannot automatically be attributed to the distribution segment. Benchmarking under the transactional net margin method must reflect the relevant segment's functional profile.

Limited recall of an appellate order permits adjudication of a ground left undecided without disturbing findings on other grounds. A challenge to the exclusion of comparables used in a transfer-pricing study is distinct from challenges concerning comparables included by the transfer-pricing officer. The omitted ground remains pending for adjudication, while the findings on other grounds remain unchanged.

Only investments that actually yield exempt income during the relevant previous year are included in the average investment value used to compute expenditure disallowance under Section 14A and Rule 8D. Investments that do not yield exempt income in that year are excluded from the calculation, even if they form part of the broader investment portfolio.

Pure questions of law arising from facts already on record may be raised before the Tribunal even if not specifically raised before the first appellate authority. Income tax adjustments under Section 143(1) are confined to those enumerated in that provision. Consideration of a disputed disallowance requires examination of the permissible scope of adjustment and the effect of a relevant subsequent Supreme Court decision, with a reasonable opportunity of hearing.

Fresh transfer-pricing references made after the omission of clause (i) of section 92BA cannot sustain adjustments for domestic transactions falling solely within that omitted category, where no surviving category is invoked. Section 92CA authorises references to determine the arm's-length price of specified domestic transactions. Section 6 of the General Clauses Act may preserve accrued obligations and proceedings following an omission unless a different intention appears; omission does not automatically extinguish earlier liabilities. A pre-omission transfer-pricing determination is distinct from a fresh post-omission reference.

Transfer pricing adjustments to the mark-up on associated enterprise support services require application of a prescribed arm's length pricing method under section 92C and Rule 10B. Characterising the services as coordination or pass-through activities alone does not support an adjustment without applying such a method. Section 43B permits deduction of specified liabilities on actual payment. IGST liability disallowed in an earlier year is deductible when paid during the relevant assessment year.

Where a return filed after a reassessment notice is accepted, failure to issue a scrutiny notice under section 143(2) invalidates the assessment. A best judgment assessment based on non-compliance is unjustified where the assessment record contains the taxpayer's response and supporting records. Accepted agricultural income and documented cash withdrawals may explain alleged unexplained money and bank credits, respectively, preventing the corresponding additions from surviving.

Reopening an assessment beyond four years after a scrutiny assessment requires the recorded reasons to identify the assessee's failure to disclose fully and truly all material facts necessary for assessment. Those reasons cannot be supplemented subsequently. Where share application money was examined and applicant details and PANs were supplied during the original assessment, reasons based on inquiries for a later year cannot support reopening without identifying a disclosure failure for the relevant year. Without that disclosure failure, the reopening notice lacks jurisdiction.

Revisional jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to the interests of the Revenue. This requirement applies where revision of block assessments is proposed on the ground that the Assessing Officer failed to inquire into seized material. Where assessment records contain explanations for seized documents and related group assessments arising from the same search involved adequate inquiry, revision on that ground is unsustainable.

Approval of an insolvency resolution plan freezes creditors' liabilities under the plan and extinguishes claims not included in it. The approved plan has overriding effect over other statutory enactments. An income-tax assessment completed after approval was liable to be quashed despite prior permission to continue assessment proceedings, where the tax department had notice of the insolvency proceedings and was included as an operational creditor.

Amounts recovered from petitioners towards tax collection at source dues on mining royalty are to be returned upon an application by the affected petitioner. Recovery notices were issued to the petitioners for those dues, which were linked to a tax demand against the Mining Department that was quashed by a Division Bench.

The pending stay application is to be decided on 20 November 2026, when the petitioner is represented, in accordance with the applicable instruction and law. Coercive recovery is barred until 21 November 2026. No determination has been made on the merits of either the stay application or the underlying tax demand.

Integrated tax credit on imports is supported by bills of entry and proof of payment and cannot be denied solely for lack of domestic-supplier reporting or entry under a different return category. Import credit is reported separately from domestic-supplier credit, and the supplier-reporting provision invoked was not in force in the relevant financial year. The related tax, interest and penalty demands could not be sustained. For the special first-appeal window, the pre-deposit was 12.5% of disputed tax, with at least 20% payable through the cash ledger. The filing deadline was separate from the payment-mode condition: an appeal filed on time with the full deposit paid through the credit ledger was not time-barred. No further cash deposit was required in the circumstances, including a cash payment at the Tribunal stage.

Section 16(2)(aa) of the Central Goods and Services Tax Act, 2017, effective from 1 January 2022, cannot support an input tax credit demand for financial year 2018-19. Section 75(7) prohibits confirmation of a demand on grounds not specified in the show cause notice. An allegation that suppliers failed to file returns does not give notice of the distinct charge that they failed to pay tax; a demand cannot be confirmed on that new ground. A demand based on these grounds, together with associated interest and penalty, cannot be sustained.

Input tax credit reported under an incorrect tax head may remain admissible if reconciliation of original records and the electronic credit ledger establishes its availability, admissibility and utilisation. The aggregate ledger balance is relevant to interest on wrongly availed and reversed IGST credit. Entitlement under section 16 of the CGST and UPGST Acts depends on cumulative conditions, including actual payment of the tax charged to the Government. Invoice reflection in GSTR-2A alone does not establish entitlement, and credit is inadmissible where the claimant does not establish the supplier's tax payment.