Foreign Tax Credit cannot be denied solely because Form No. 67 was furnished after the return-filing due date where foreign income was disclosed and foreign tax payment is verifiable. Rule 128(9) prescribes the filing timeline but does not attach denial of credit to delay, while section 90 imposes no such time limit and Rule 128(4) identifies the circumstances for denial. The timing requirement is therefore directory and cannot defeat substantive relief from double taxation. The later permission to furnish Form No. 67 until the end of the assessment year supports allowing the credit despite delayed filing.

Donations made by a charitable trust to further its charitable objects may be deducted in computing income from other sources under Section 57(iii) where the trust is assessed as an AOP and does not claim exemption under Sections 11 and 12. Expenditure incurred to carry out those objects is treated as deductible; denying the deduction would subject gross receipts, rather than income, to tax. Qualifying donations to charitable institutions in furtherance of the trust's objects are therefore allowable in computing income from other sources.

Section 69A requires jewellery to be assessed as unexplained only where the taxpayer's explanation of its nature and source is unsupported. Consistent historical wealth-tax records, valuation reports, family-distribution evidence and physical verification can explain inherited or long-held jewellery; non-filing of wealth-tax returns alone does not prove disposal. Accordingly, the disclosed jewellery was treated as satisfactorily explained. Brokerage for property identification and negotiation is ordinarily personal-service income and cannot be attributed to an HUF without a real nexus to HUF funds or assets. Where the individual service provider was separately paid for the same transaction, an additional HUF payment was not established as deductible investment cost.

Land-MoU receipts claimed as advances for co-owners require evidence of the co-owners' entitlement, the governing arrangement and the receipt's character. Where no such evidence exists, the funds are retained and used solely by the recipient, and repayment is not required upon adverse title determination, the receipts are treated as taxable income rather than advances. Bank credits remain unexplained where stated sources and confirmations do not reconcile and no substantiating material is produced. However, cash already included within an assessed MoU receipt cannot be separately added unless shown to have been received over and above that receipt.

Section 68 requires the assessee to establish the creditor's identity, creditworthiness and the genuineness of each credit for the relevant assessment year. Section 56(2)(viib) and the later source-of-source proviso to section 68 do not apply retrospectively. Bank entries, corporate records and audited accounts may support identity and fund movement, but neither those records nor factors such as low taxable income, high share premium or unusual banking patterns conclusively establish genuineness. Where receipts comprise distinct transactions, they require transaction-wise examination. Verification of financial capacity, antecedent credits, commercial rationale, valuation and underlying investments, with disclosure of adverse material and rebuttal opportunity, is required before determining the addition.

Book profit for partners' remuneration includes commercial profit credited to the profit and loss account on transfer of a depreciable business asset, even where the amount is deemed short-term capital gain for capital-gains computation. Explanation 3 to Section 40(b) relies on net profit shown in the profit and loss account, computed under Chapter IV-D, subject to the prescribed remuneration adjustment; it does not exclude every receipt assessed under another income head. Section 50's deeming fiction is confined to capital-gains computation and does not displace commercial profit for book-profit purposes. Revenue neutrality cannot create a deduction, but actual payment and taxation of otherwise permissible remuneration may support its bona fide character.

Natural justice does not invariably require oral hearing where written submissions provide an effective opportunity of representation and are considered in adjudication. Refusal of an adjournment for oral arguments, despite consideration of the Revenue's detailed written submissions and material contentions, does not by itself establish prejudice or denial of natural justice. Rectification under Section 254(2) is confined to a material contention apparent from the record having been overlooked and causing prejudice; it cannot be invoked to seek a merits review because additional oral submissions were not permitted. Recall or rectification was therefore not warranted.

Section 69A does not apply to cash deposits recorded in books and traceable to disclosed cash sales or debtor realisations merely because the explanation is doubted. Where turnover and business profits remain accepted, and no evidence establishes fictitious sales, an unrecorded source, or material outside the books, a separate addition for unexplained money would duplicate taxation of disclosed business receipts. Rejection of books under Section 145(3) requires specific defects preventing correct income determination; suspicion based on cash-receipt patterns or cash retention, without inquiry or evidence of falsity, is insufficient. Recorded cash from accepted business turnover therefore cannot be separately assessed as unexplained money.

For Assessment Year 2025-26, Section 87A grants a full rebate to a resident individual governed by Section 115BAC(1A) whose total income is within the prescribed limit, including against tax attributable to short-term capital gains taxable under Section 111A. The first proviso to Section 87A, applicable from Assessment Year 2024-25, contained no exclusion for special-rate income. The Finance Act 2025 exclusion of such income applies only from Assessment Year 2026-27 and does not affect Assessment Year 2025-26. Consequently, eligible taxpayers may claim the rebate against tax on qualifying short-term capital gains for that year.

Section 54F deduction for construction of a residential house requires construction within three years of transfer and evidence supporting the eligible investment. A local-authority certificate and registered valuer's report supported timely construction of the residential house and the related construction expenditure. Expenditure claimed for furniture and fixtures lacked sufficient supporting evidence and was excluded from the eligible investment. The resulting computation allowed deduction for the supported residential-house construction and determined the remaining long-term capital gain after excluding unsupported furniture and fixture costs.

Reassessment cannot sustain a disallowance of deduction under Section 80P where no addition is made on the cash deposits and time deposits that formed the recorded reasons for reopening. Under the applicable jurisdictional principle, failure to make an addition on the reopening issue prevents assessment of another issue in that reassessment. The Section 80P deduction disallowance was therefore beyond the permissible scope of reassessment and was deleted.

Survey surrender income credited to the profit and loss account and offered as business income was subject to the normal tax rate for Assessment Year 2017-18. Section 115BBE's enhanced rate took effect from 1 April 2017 and, without express retrospective operation, applied from Financial Year 2017-18, corresponding to Assessment Year 2018-19. Where two reasonable interpretations of a taxing provision were available and no jurisdictional High Court ruling governed the issue, the interpretation favourable to the taxpayer applied. The enhanced rate therefore did not govern the surrendered income for the relevant assessment year.

Obsolete inventory may be written down to net realisable value under Accounting Standard-2's lower-of-cost-or-net-realisable-value principle where the valuation is consistently applied and supported by audited accounts, physical verification, item-wise stock records, business discontinuance and auditor certification. A higher value cannot be substituted merely on presumed scrap value, lack of technical certification, non-disclosure to a banker or later stock-summary omissions. Independent valuation evidence, comparable sales, market quotations, scrap valuations or other positive material is required to establish a higher realisable value. Acceptance of the closing stock as succeeding-year opening stock further supports the commercial basis of the write-down.

Summary processing under Section 143(1) may occur before regular scrutiny assessment begins. Once notice under Section 143(2) initiates scrutiny proceedings, a later intimation under Section 143(1) is unnecessary and impermissible. Where the scrutiny notice predates the summary intimation, the intimation is void from inception; adjustments made through it cannot stand, and the returned income must be accepted.

Section 69A applies only where money is unrecorded in the books and its nature and source lack a satisfactory explanation. Cash deposits linked to cash-book entries, documented paddy sales, financial statements and business financing require evidence that the recorded transactions are fictitious before they can be treated as unexplained money. Unrejected books and an undisproved stock, purchase and sales trail prevent recharacterisation of recorded business receipts, avoiding taxation of the same receipt under two characterisations.

Reassessment cannot sustain an addition on an issue outside the recorded reasons when the addition on the reopening issue does not survive. The land-transaction addition that prompted reassessment was deleted without challenge by the Revenue. Consequently, the separate addition under Section 50C for short-term capital gains from sale of shops, being unrelated to the recorded reasons, was deleted in favour of the assessee.

Before 1 April 2025, the Joint Commissioner held authority to impose penalties for contravention of Section 269SS, while the Assessing Officer lacked jurisdiction to initiate or impose penalty under Section 271D. Accordingly, an Assessing Officer's failure to initiate such penalty proceedings could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision purposes under Section 263. Revision on that ground was therefore invalid, and the revision order was set aside in favour of the assessee.

Sanction under Section 151 of the Income-tax Act is a jurisdictional condition for reassessment notices issued after the applicable three-year period. For assessment year 2017-18, a notice issued after 31 March 2021 required prior approval from the prescribed Principal Chief Commissioner-level authority. Approval by a Principal Commissioner did not satisfy that statutory requirement. Consequently, the reassessment notice was invalid because it lacked sanction from the specified authority.

Clause 2(c) of the 2006 waiver/reduction order permits interest relief only where non-payment resulted from a jurisdictional High Court order governing the assessee when advance tax was payable or the return was filed, and where the full principal tax demand has been paid. Returns filed before the relevant judicial ruling cannot satisfy the reliance requirement; failure to pay the principal demand also defeats relief. Provisions on interest following reassessment or recomputation do not invalidate a refusal of waiver. Interest under Section 220(2) arises on default after a demand notice, and any excess levy claim requires consideration by the competent authority, including a possible refund.

Approved resolution plans bind all stakeholders and enable a corporate debtor to resume operations on a fresh slate. Income-tax arrears not submitted before the committee of creditors and not included in the resolution plan are frozen upon the adjudicating authority's approval. Such unclaimed tax demands do not survive against the corporate debtor after approval, preventing recovery of liabilities excluded from the plan.