The first proviso to Section 149(1)(b) retains the pre-amendment limitation regime for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, the six-year period expired on 31 March 2022. The amended extended limitation period cannot operate retrospectively to revive a reassessment notice already barred under the earlier regime. Exclusions of time connected with Section 148A proceedings do not override the proviso's limitation restriction. Consequently, the notice issued on 7 April 2022 was time-barred, and the consequential reassessment order was quashed.

Additional evidence omitted because of a former tax consultant's failure and an ex parte first-appellate order may be considered in the interest of justice. Cash-payment disallowance requires verification of whether each voucher records payment to one person exceeding the prescribed daily threshold or aggregates payments to multiple labourers that individually remain within the permissible limit. The Assessing Officer must examine the underlying payment particulars rather than treat the voucher total as conclusive. Fresh adjudication may follow after admitting the evidence, with all contentions remaining open.

Related-party advertising expenditure under section 40A(2)(b) requires objective evidence that payment exceeds fair market value; reliable comparable rates shift the evidentiary burden to the Revenue, and the advertising disallowance cannot be sustained without contrary material. Programme production for broadcasting or telecasting falls within contractual work under section 194C rather than professional or technical services under section 194J where the underlying transactions are substantiated. Advertising revenue accrues when an enforceable right to receive arises, not merely on invoice issuance, requiring verification where services span later periods and preventing double taxation. Commission provisions require proof of accrued liability and services rendered, without duplicate disallowance of sums already disallowed for tax-deduction default.

Rectification under section 254(2) is confined to a patent, manifest and self-evident mistake apparent from the record. Previously considered seized material, related-party orders, alleged on-money receipts and precedents on income extrapolation cannot be re-examined merely because an assessee disputes their interpretation or asserts factual parity. The provision does not permit reappreciation of evidence, replacement of a possible view, reconsideration of factual findings or review of appeal merits. No mistake apparent from the record arose, so rectification was declined.

Reassessment beyond four years after a completed scrutiny assessment requires recorded reasons that independently establish tangible material indicating income escapement and the taxpayer's failure to make full and true disclosure of material facts. Reasons must stand alone and cannot be supplemented subsequently. Where the original assessment obtained shareholder identities, PANs, confirmations and banking details, alleged accommodation-entry information must reliably link the identified shareholder to the purported entry provider. Shareholders' non-compliance with summons does not cure deficient recorded reasons. Reopening lacked both tangible material and an identified disclosure failure, rendering the reassessment void ab initio.

Section 54 permits deduction for investment in a new residential house where construction is completed within the prescribed period after transfer of the original house; construction need not commence only after that transfer. Where the plot was acquired before transfer and registered in the spouse's name, its cost was not eligible on the stated facts. Separately ascertainable construction expenditure remained eligible despite exclusion of the land component. Deduction was therefore confined to the eligible construction cost, while the land cost was excluded and the remaining capital gain was taxable.

Identified commission receipts arising from disclosed business activity cannot be treated as unexplained cash credits merely because they were received in cash, absent material showing a separate undisclosed source; only income embedded in those receipts may be taxed. Cash introduced by a proprietor into a proprietary concern likewise cannot be characterised as unexplained where available business cash supports it, since the concern lacks a separate legal identity. Conversely, unreconciled personal expenditure exceeding recorded withdrawals is taxable as unexplained expenditure where the taxpayer provides no cogent explanation or evidence of an explained source. Accordingly, additions for business receipts and proprietor cash were deleted, while the personal-expenditure addition was sustained.

Stamp-duty-value addition under Section 56(2)(x) depends on whether, where an agreement date differs from the registration date, consideration was fixed under the prior agreement and paid through a prescribed non-cash mode on or before that date. Evidence of the agreement, payment timing and banking-channel payments requires verification to identify the applicable proviso and appropriate stamp duty value. No merits determination arises until those facts are verified.

Section 54F is a beneficial capital-gains exemption provision that calls for liberal interpretation. Its conditions do not require the cost of a new residential house to be funded exclusively from the sale proceeds of the original capital asset or solely through withdrawals from the capital gains account. Timely deposit of sale consideration in that account meets the statutory deposit requirement. Investment records and municipal tax assessment evidence may establish construction of the residential house within the prescribed three-year period, supporting entitlement to exemption where the remaining statutory conditions are met.

Leave-encashment received by a non-government employee qualifies for exemption under Section 10(10AA) within the enhanced limit prescribed by Notification No. 31/2023. The enhanced limit applies retrospectively, supported by the explanatory memorandum confirming that no person is adversely affected by retrospective application. Where the factual and legal position remains unchanged, exemption cannot be restricted to the former lower limit. Accordingly, the stated leave-encashment receipt falls within the enhanced exemption threshold.

Reasonable cause for delayed filing was established by the taxpayer's residence shift, overseas employment and non-receipt of hearing notices, warranting condonation and merits adjudication. Audited accounts, books, transaction bills, creditor confirmations and supporting statements substantiated the cash deposits and unsecured loans. An inspector's report not confronted to the taxpayer could not wholly displace that evidence under natural justice principles. The additions were consequently confined to an aggregate amount over returned income, with the remaining addition deleted and income to be recomputed.

Section 69 applies only where the assessee made an investment that was not recorded in its books and whose nature and source remained unexplained. Payments made before the assessee firm existed, and confirmed as payments by a predecessor firm, could not constitute the assessee's investment merely because it assumed the related project liability. Any unexplained cash source required examination in the predecessor firm's assessment. Cash-flow details, buyer particulars and bank entries were not displaced through enquiry, and suspicion could not substitute evidence. A bank payment subsequently returned to the payer did not establish a separate cash payment without corroboration. No unexplained investment arose, and the related addition, tax treatment and interest were deleted.

Cash-balance additions based solely on the difference between opening and closing cash are unsustainable where the opening balance is carried forward from audited accounts, the books remain unrejected, and no individual cash receipt or payment is identified as unexplained. Brought-forward cash is not a fresh credit or receipt of the relevant year unless material establishes that it did not exist or represents current-year income. In the absence of false or unverifiable cash-book entries, the cash-balance addition was deleted.

Ordinary territorial jurisdiction for an appeal and cross-objection follows the location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the appellate authority. Where the originating assessment order was issued by an Assessing Officer at Chennai, the Mumbai Bench lacked jurisdiction over both proceedings. The parties may pursue them before the appropriate jurisdictional Bench, with merits remaining open.

Valid and timely notice under Section 143(2) must be issued by the competent jurisdictional Assessing Officer for an assessment under Section 143(3). A notice issued after the statutory deadline cannot sustain the assessment. An earlier timely notice issued by a non-jurisdictional officer is ineffective unless jurisdiction was validly transferred under Section 127. Without a valid transfer order and timely notice by the competent officer, the assessment is void ab initio, and relief to the assessee stands sustained.

Cash-deposit verification relief applies to an individual without business income for demonetisation-period deposits up to Rs. 2.50 lakh, reducing the addition to that extent while sustaining the balance. For Assessment Year 2017-18, ambiguity over the temporal application of the amendment increasing the Section 115BBE rate was addressed through the favourable interpretation of a taxing provision. The enhanced rate was treated as applying only to transactions from 1 April 2017; the surviving addition was therefore taxable at the pre-amendment rate.

Discounted Cash Flow valuation permitted under Section 56(2)(viib) and Rule 11UA must be assessed using information available on the valuation date. Subsequent financial performance or initial operating losses alone do not establish that contemporaneous projections were unreliable or justify replacing the valuation with the Net Asset Value method, particularly where an independent report supports the assumptions. Section 69C applies only where the source of expenditure remains unexplained. Differences between recorded expenditure and vendor confirmations do not constitute unexplained expenditure when entries appear in audited books, payments are made through banking channels, and the business source of those payments is undisputed.

Section 14A read with Rule 8D does not support a disallowance where investments neither yielded nor could yield exempt income, dividend income was taxable in the relevant assessment year, and recorded expenses related to taxable income. Rule 8D may be invoked only after the Assessing Officer records valid satisfaction regarding the assessee's claim. On these facts, including consistency with accepted positions in earlier and subsequent years, the Section 14A disallowance was deleted.

Accepted sales and unrejected books of account preclude treating the entire value of alleged bogus purchases as non-genuine when those purchases support recorded sales. The taxable addition is confined to the profit element embedded in purchases from non-genuine suppliers. On the stated facts, a 12.5% gross-profit estimate was excessive, and the addition was limited to 5% of the disputed purchases as business income.

Cash deposits during demonetisation recorded in unrejected audited books and supported by verifiable prior bank withdrawals satisfy the source-explanation requirement for unexplained cash credits. Where books are not rejected and bank records substantiate withdrawals and subsequent deposits, the deposits cannot be treated as unexplained income. The enhanced tax rate with surcharge under section 115BBE does not apply for assessment year 2017-18. Accordingly, additions for the cash deposits and their treatment as unexplained income were unsustainable.