Benami seizure procedure: serve notice by affixation, assess by best judgment, levy penalty and proceed to recovery promptly.
Where unaccounted stocks are seized in benami or fictitious names, the territorial ITO must issue a notice under section 139(2) and serve it by affixation to the ITO notice board and relevant custodians. If there is no response, complete assessment under section 144 taking investment value as income invoking sections 68 and 69; initiate penalty proceedings with short notice and, after expiry, levy penalty. Issue recovery certificate to the TRO, attach bank deposits, and proceed to attach/auction seized assets. Maintain jurisdictional control and supervisory oversight by Director of Inspection/Commissioner.

Appellate order timelines: requirement to issue appellate orders within ten days after final hearing and on transfer.
Departmental appellate authorities must pass appellate orders within ten days of the final hearing, and this timeline applies even when the AAC or CIT(A) has been transferred; after an order of transfer no new hearings are to be taken up and part-heard cases must be stopped, and orders should be passed before relinquishing charge on transfer or proceeding on leave.

Relief under section 80-J: compute new industrial undertaking profits separately; set offs against other income disallowed.
Relief under section 80-J requires computing profits of a new industrial undertaking as a separate business, applying the normal heads-of-income rules, and not allowing expenses, allowances or unabsorbed depreciation of that undertaking to be set off against profits or income of other units or heads when determining the relief for the undertaking.

Monetary threshold raised for judicial escalation, altering when cases qualify for higher court reference and appeal.
The Board revised monetary limits governing judicial escalation in income-tax matters: the threshold for reference to the High Court is raised to Rs.30,000 and the threshold for appeal to the Supreme Court is raised to Rs.60,000, superseding the earlier lower limits and guiding when departmental cases qualify for High Court reference and Supreme Court appeal.

Search disclosure obligations require informing customs, excise and enforcement agencies about specified seized items during tax searches
Authorised Officers conducting income tax searches must promptly notify specified sister agencies when particular items are found-foreign currency, primary gold and excess sovereigns, imported goods not cleared or above a value threshold, unlicensed firearms, and certain quantities of liquor-so those agencies can take action under their own laws; the Board reiterates earlier circulars, notes noncompliance by some officers, identifies the authorities for each category, and warns that failure to follow these notification instructions will be viewed adversely.

Special Leave Petition filing: procedure after High Court rejects department reference, central processing and ministerial approval required.
When a High Court rejects the Department's reference under Section 256(2), a Special Leave Petition may be filed under Article 136 without awaiting field reports or certified copies if filed within the normal limitation period. Internal processing moves from the Board to the Ministry of Law, to the Central Agency for the Senior Law Officer's opinion, back to the Board for Ministerial approval, then to the Central Agency for petition preparation; the advocate on record drafts the petition, the Central Government Advocate vets it, and the Under Secretary, CBDT signs fair copies. Proposals should reach the Board at least 45 days before limitation; same applies to WT, GT and ED SLPs.

Key identification: record seized key numbers to prevent substitution; sealed lockers must be operated within a week.
Seizure procedures require that each seized key's number be recorded in the seizure memorandum to prevent substitution, with the key number alone entered if linkage to a bank locker is disputed. Sealed bank lockers resulting from searches must be operated within one week, and any locker remaining sealed beyond that period must be reported to the appropriate investigative authority.

Limitation for revision orders clarified under income-tax law; authorities urged to act promptly to avoid litigation.
Amendment extends the applicable limitation where the original statutory period had not expired before 1 October 1984, applying statutory interpretation to continue the limitation for revision powers under section 263; administrative guidance advises completing revisions of assessments passed before that date within two years to minimise controversy and litigation.

Effective date of order is the date of signing; orders must be dated upon signature to prevent antedating.
The instruction holds that the effective date of an order is the date on which it is actually signed, not the date it was dictated, and mandates that orders bear the actual date of signature; antedating is prohibited and signatures should always be dated.

Coordination among assessing officers: supervisory directions should trigger cross tax action when assessment records reveal related issues.
Provision under Section 144A permits Assistant Commissioners to examine records of pending assessments and issue directions to Income Tax Officers to complete assessments; while doing so they must scrutinise files for clues relevant to other direct tax statutes and, if such matters are found, issue separate instructions to initiate or coordinate action under those statutes.

Assessment coordination: partners' tax assessments must follow firm assessments to ensure partner assessments reflect final profit shares.
Assessing officers must coordinate timing and content of partner assessments with the firm's assessment: where the same officer assesses both, partners' assessments should be completed only after the firm's assessment; where different officers are involved, the partner's officer must obtain the firm's assessment order. If a partner is assessed earlier, the firm's officer must communicate the firm-determined share of profits so the partner's assessment can be rectified.

Restrictive orders under section 132(3) are short-term: investigate stock source, release on bank guarantee or realise.
Restraint orders under section 132(3) are a short-term measure and should not be prolonged. For stocks, do not issue orders for perishable goods; promptly investigate source and extent of unexplained investment and compute tax, penalty and interest. Release stock on unconditional bank guarantee for the computed amount, and if the assessee refuses, pursue realisation through auction under enforcement provisions. Review all pending restraint orders on stock in light of these instructions.

Exemption under section 10(21) requires approved scientific research associations to apply income solely and meet investment conditions.
Section 10(21) exempts income of a scientific research association approved under section 35(1)(ii) when applied solely to the association's purposes; the income need not be spent in the relevant year. The Finance Act, 1983 amended section 10(21) to require post-cut-off contributions to be invested or deposited in prescribed forms and to bring prior investments into the prescribed pattern, and to restrict investments in companies to government companies or statutory corporations. Authorities should issue notices and scrutinise returns to verify compliance.

Donations between charitable trusts: exemption under Section 11 depends on tax officer's satisfaction that funds will be used for charitable purposes.
Donations by one charitable trust to another will not automatically be treated as application of income for charitable purposes under Section 11 for the donor; the income tax officer must be satisfied, based on facts and circumstances, that the donated funds will be utilised exclusively for charitable purposes by the donee trust before granting the donor exemption.

Exclusion of agricultural land from estate duty ends levy on qualifying farmland following statutory commencement and rule making procedures.
The Amendment discontinues estate duty on agricultural land by excluding such land from levy under the principal Act, prescribes territorial application and commencement for specified States and Union territories and for other States upon legislative adoption, omits aggregation provisions for rate determination related to exempt State holdings, and revises the parliamentary laying and modification procedure for rules made under the principal Act while preserving prior valid acts under those rules.

Tax exemption for sports associations requires government approval plus strict income application, non distribution compliance, and audited accounts proof.
Section 10(23) grants tax exemption to associations or institutions for specified sports only if three cumulative conditions are met: application or accumulation of income solely to the entity's sporting objects; prohibition on distribution of income to members except as grants to affiliated bodies; and approval by the Central Government. Government approval alone does not satisfy the other two conditions, and audited accounts must be filed with the Income tax Officer to demonstrate compliance.

Time limit for search-and-seizure summary orders extended, but prior seizures remain subject to the original deadline.
The amendment lengthens the statutory period for an officer to pass a summary order under sub-section (5) of section 132 for estimating undisclosed income after search and seizure, effective from 1 October 1984. The Board clarifies that seizures made on or before 30 September 1984 remain subject to the prior, shorter time limit, while the extended period applies to seizures after that date.

Safe custody of seized assets requires joint deposit/operation by two senior officers with records and handover memos maintained.
Where departmental strong rooms are unavailable, bank lockers must be jointly operated by two senior officers (with specified officer composition at Commissioner's headquarters) and Registers I and II maintained; if lockers are unavailable or undersized, sealed packages must be placed in a strong sealed bag with identification tag and deposited in the joint names of two senior officers with RBI, SBI or subsidiary, Nationalised Banks, or Government Treasuries, recorded in Register II, and complete handing over memos must be drawn on transfer or retirement.

Conversion of capital asset into stock-in-trade treated as transfer, triggering capital gains tax when subsequently sold.
Conversion or treatment of a capital asset as stock-in-trade is to be regarded as a transfer for capital gains; the fair market value on the date of conversion is deemed the full value of consideration and capital gain is charged in the year the stock-in-trade is sold. A new section 47A withdraws exemption on transfers between a company and its wholly-owned subsidiary where within eight years the asset is converted to stock-in-trade or whole ownership of share capital ceases, and section 49 fixes the transferee's cost where deemed gains are taxed.

Scope of 'attributable to' broader than 'derived from', apply that interpretation to similar tax assessment issues.
The textual phrase 'attributable to' has a broader scope than the phrase 'derived from', and that interpretive conclusion renders the earlier Instruction No.596 inoperative; questions of a similar character should be decided in light of the broader meaning of 'attributable to'.