Section 56(2)(vii) did not support an addition where the difference between purchase consideration and DVO valuation fell within the applicable tolerance band. The Section 50C(2) valuation mechanism was treated as pari materia, extending its tolerance to that valuation difference; the stamp-duty-based addition was therefore deleted. Investment and stamp-duty payments traceable to the taxpayer's disclosed bank account and available balance constituted an explained source of funds. The unexplained-investment addition was consequently deleted, resulting in deletion of both property-acquisition additions.

Business-expenditure deductibility under sections 28(i) and 29 requires an expense-wise factual inquiry into whether legal and professional costs were incurred for continuing or preserving the business. Transfer of a branch undertaking on a going-concern basis did not itself resolve the position where statutory assets remained with the taxpayer. As the purpose of retaining those assets and the connection of the predominant expenses with business purposes or pending branch litigation were not established, the claim against interest on an income-tax refund requires fresh determination through de novo assessment.

Differences between FCRA disclosures and income-tax return reporting cannot be treated as undisclosed income through a section 143(1) adjustment merely because the FCRA figure includes interest earned on invested foreign contributions. FCRA and income-tax disclosures serve different statutory purposes and require reconciliation based on substance rather than form. Where foreign contributions and related interest are separately declared, accounts are audited without qualification, the reporting approach has been accepted in other years, and supporting explanations are provided in rectification proceedings, a prima facie adjustment is unsustainable. The addition was deleted.

Penalty for an alleged breach of cash-transaction restrictions requires cogent proof of the underlying cash receipt, even though penalty proceedings are independent of assessment proceedings. The Revenue did not produce demonstrative evidence supporting the alleged cash receipt used as the basis for penalty; the larger amount rested on conjecture and differed from the amount recorded in the available material. As the essential cash transaction was not proved, penalty was not leviable.

Appellate confirmation of a penalty exceeding the Assessing Officer's levy requires prior notice of enhancement. Erroneous entries in an appeal form that record surrendered income as penalty amounts do not justify confirming a higher penalty without that notice. Penalties therefore remain restricted to the amounts originally levied, although liability for penalties at those original amounts remains sustainable on the recorded facts.

Section 144C treats objections to a draft assessment order filed after the prescribed thirty-day period as time-barred. Where no valid objections exist, the Assessing Officer must complete the assessment under the draft-assessment procedure within one month from the end of the month in which the objection period expires. This statutory limitation is mandatory and is not extended by pending disposal of belated objections before the DRP. A final assessment order made after that period is void ab initio and liable to be quashed.

Rectification orders under Section 154 are appealable under Section 246A, and dismissal of such an appeal as non-appealable cannot deny merits-based consideration of a claim for the concessional tax rate under Section 115BAB. Allocation of an appeal to a particular first appellate authority under the faceless regime does not prejudice the taxpayer's statutory right to appellate review. The concessional-rate claim requires adjudication on merits by the first appellate authority in accordance with principles of natural justice.

Assessment and consequential rectification founded solely on a revision order cannot survive after that revision order is quashed. The loss of the revision order removes the legal foundation for both consequential actions, rendering them non est. A pending Revenue challenge does not independently preserve the assessment or rectification where the sole revisionary foundation no longer exists.

Relevant shipping income under the Tonnage Tax Scheme is confined by section 115VI and Rule 11R to core ship-operating or dredging activities and prescribed incidental activities with a direct operational nexus. Scrap, empties, waste oil, exchange differences, insurance claims and provision write-backs qualified, while tender-document receipts, liquidated damages, salary recoveries, training fees and other operating income did not; service charges received differing treatment across the relevant assessment years. Sponsorship for the Maritime India Summit was deductible under section 37(1) because it promoted business activities and had a commercially expedient connection with future operations, despite being described as a donation.

Functional similarity is the primary criterion for selecting comparables under the Transactional Net Margin Method for routine IT-enabled back-office services; companies performing specialised, higher-value services should be excluded despite meeting quantitative filters. Employee-cost filters cannot be applied mechanically where costs are embedded in service expenses or disclosed only at entity level; functionally similar companies should not be rejected solely on that basis. Outstanding receivables may constitute an international transaction, but a separate notional-interest adjustment requires proof of an independent financing arrangement and economic benefit beyond working-capital effects already reflected in the profit-level indicator. The arm's length price is recomputed using the revised comparable set without a separate receivables adjustment.

Intra-group services' arm's length price must be determined using a prescribed transfer-pricing method and substantiated facts, rather than fixed at nil without adequate basis. Agreements, invoices, emails and an independent accountant's cost-allocation certificate supported the rendering of services. Where identical arrangements in earlier assessment years had been accepted and no distinguishing facts existed, pending departmental appeals against those earlier determinations did not displace their relevance. The arm's length price could not be determined at nil, and the transfer-pricing adjustment was deleted.

For reassessment notices for assessment year 2015-16 governed by the pre-1 April 2021 regime, the extended limitation period under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not alter the prescribed sanctioning authority. Section 151(2) required prior satisfaction of the Joint Commissioner before issuing a notice under section 148. Approval by the Principal Commissioner could not replace that statutory requirement. A notice issued without sanction from the competent Joint Commissioner was invalid, rendering the consequential reassessment proceedings and assessment order null and void.

Cash deposits of specified bank notes received from members towards crop and tractor loan recoveries cannot be treated as unexplained cash credits under Section 68 where regularly maintained books, member-wise details and the loan-repayment nexus satisfactorily establish their nature and source. The later restriction on specified bank notes does not itself negate the explained character of recorded credits. Taxing such disclosed gross receipts again as unexplained credits would result in double taxation. The receipts are to be treated as business receipts, with deduction under Section 80P available in accordance with law.

Revision jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue. Absence of enquiry into the actual use of borrowings and the possible capitalisation of related interest can justify fresh examination. Revision cannot, however, direct fishing or roving verification without identifying a specific error causing prejudice. Where the Assessing Officer has examined expenditure records, tax-deduction particulars, contractual materials and treaty applicability, a plausible view reached after enquiry cannot be replaced through revision. Accordingly, fresh examination is confined to the interest-capitalisation issue, while directions concerning tax deduction on payments to Government authorities, miscellaneous expenditure and service-provider charges are unsustainable.

Charitable registration renewal requires verification that any alleged breach of another law concerns legislation applicable to the applicant. Non-registration under the Rajasthan Public Trust Act cannot be treated as material non-compliance where the applicant, including an Urban Improvement Trust, may fall within the statutory exclusion for trusts administered by State-controlled agencies or local authorities. Deficiencies in Form No. 10AB or supporting material that can be cured must be specifically notified, with an effective and reasonable opportunity to provide documents or clarifications. Continuation of registration must then be assessed on complete material after determining the Act's applicability and curing identified defects.

Eligibility for the concessional corporate tax regime under Section 115BAA is examined where Form 10-IC was created and saved on the income-tax portal by the due date but filed late because of a technical glitch. Portal records evidencing a genuine, timely attempt to exercise the option are relevant to the delay. The condonation approach under CBDT Circular No. 6/2022 addresses genuine hardship arising from such technical failures and supports assessment under the concessional regime.

The proviso to Section 12A(1)(ac), effective from 1 October 2024, empowers the Principal Commissioner or Commissioner to condone delay in filing Form No. 10AB for regularisation of provisional registration where reasonable cause is established. An application filed after the prescribed period cannot be rejected solely as time-barred without examining that statutory discretion. A bona fide misunderstanding regarding the duration of provisional registration may require consideration as reasonable cause, although a substantial delay must be specifically assessed by the competent authority. Strict-compliance principles do not override an express statutory power to condone delay.

Section 80G(5B) treats an institution or fund with religious expenditure not exceeding five per cent of its total income during the relevant previous year as eligible for section 80G, notwithstanding religious or religious-cum-charitable objects. Explanation 3 excludes purposes that are wholly or substantially wholly religious from charitable purpose, but does not displace this statutory threshold. Approval cannot be refused solely because of religious objects without verifying actual religious expenditure. Eligibility depends on compliance with the five per cent limit and the remaining statutory conditions.

Cost-to-cost reimbursements received from Indian associated enterprises for third-party event, legal, professional, employee welfare and recruitment expenses were not taxable in India where the underlying activities were performed remotely without employees or personnel being physically present in India. A service permanent establishment under Article 5(2)(l) of the India-USA tax treaty requires services to be furnished or performed in India through employees or other personnel for the stipulated duration. As those cumulative conditions were not met, no service permanent establishment arose and the reimbursements did not constitute income chargeable to tax in India.

Corporate guarantees issued for associated enterprises are treated as international transactions requiring arm's length benchmarking under Section 92B of the Income-tax Act. Where the assessee's bank facility letter provides a reliable internal comparable uncontrolled price, that rate is preferred to unadjusted external bank guarantee rates because bank and corporate guarantees differ in creditworthiness, security and risk. The corporate guarantee commission is restricted to 0.60%, after credit for commission recovered from associated enterprises. Additional TDS/TCS credit requires verification of supporting factual material before relief may be granted.