Penalty proceedings for concealment of income or furnishing inaccurate particulars require a notice identifying the precise charge. Retaining both alternative limbs in a notice, without striking out the inapplicable limb, leaves the taxpayer unable to determine the alleged default. Under Sections 274 and 271(1)(c), this defect in initiation renders the notice invalid and prevents the consequential penalty order from being sustained. Clear communication of the applicable statutory basis is required before imposition of a penalty.

Interest earned by a co-operative credit society on its own funds temporarily placed in deposits with nationalised or scheduled banks is attributable to its business of providing credit facilities to members and qualifies for deduction under section 80P(2)(a)(i). "Attributable to" is broader than "derived from". Treatment as income from other sources does not apply where deposited funds are neither amounts payable to members nor other liabilities.

Cash gifts from relatives are not assessable as unexplained cash credits where the recipient establishes donor identity, transaction genuineness and basic creditworthiness. Donor confirmations responding to statutory notices, gift deeds, income-tax returns and financial statements satisfy the initial evidentiary burden. Revenue doubts concerning donors' own sources amount to requiring proof of the source of source and cannot, without independent material, establish that the gifts are the recipient's unexplained money. Comparisons between returned income and gift amounts, or mere suspicion, do not rebut recorded gifts. The gifts were satisfactorily explained, and the addition was deleted.

Reassessment limitation excludes the period allowed for responding to a Section 148A(b) notice when computing the period under the proviso to Section 149(1). Exclusion of the notice-reply period brought the reassessment notice within the applicable three-year period, making approval by the PCIT competent under Section 151(i). A political-party donation is not deductible under Section 80GGC merely because it was paid through banking channels and supported by a receipt. Investigation material showing funds routed through intermediaries and returned to donors established an accommodation-entry arrangement; absent credible rebuttal, the claimed deduction was unsustainable.

Section 80-IA(4) allows infrastructure-facility deductions for enterprises that develop, operate and maintain, or develop and operate qualifying facilities, subject to statutory conditions. EPC contractor status alone does not preclude developer eligibility; the substance of contractual responsibilities and activities governs. Responsibility for design, procurement, execution, testing, commissioning, maintenance, project risks, and deployment of technical and financial resources supports developer status. Where substantially identical claims were accepted in earlier years and no material factual or legal change exists, the deduction remains available and disallowance is deleted.

Clerical omission of income-from-other-sources particulars from a return schedule does not justify an unexplained-money addition where that income was included in taxable income and the related liability was paid through advance tax, tax deduction and self-assessment tax. Consistent disclosures in preceding and succeeding years support treatment of the omission as inadvertent. Directions allowing a Tribunal challenge without applying limitation, while excluding the pendency period of related proceedings, rendered the appeal maintainable when filed immediately after receipt of the relevant order. The unexplained-money addition was consequently set aside.

Cost of improvement in computing capital gains must be attributable to the capital asset or ownership interest transferred. Where jointly owned land is improved but an assessee transfers only a one-tenth interest, expenditure cannot be deducted in full merely because the assessee incurred it or other co-owners made no claim. Without a legally enforceable arrangement or cogent evidence entitling the assessee to set off the entire expenditure against proceeds from the individual share, deduction is restricted to the proportion corresponding to the transferred interest. Accordingly, only one-tenth of the improvement cost is allowable.

Condonation of delay may be warranted where COVID-19 disruption, flood-related relocation, limited staffing and professional default collectively establish sufficient cause. Deduction under section 80P(2)(a)(i) requires examination of annual accounts and identification of income attributable to eligible business activities. Additions for unexplained cash deposits require verification of the assessee's explanation and supporting member KYC particulars after an effective hearing. Quantum and consequential penalty matters require fresh determination on a complete factual record, with penalty consequences dependent on the revised quantum outcome.

Ad hoc disallowance of purchases as business income was unjustified where purchase records, supplier confirmations, bank statements, invoices, stock records and transport evidence supported the transactions. Corresponding purchase and sales quantities, predominantly banking-channel payments, and minimal cash purchases weakened any allegation of bogus purchases. Absence of GST registration or GST numbers on invoices did not support an adverse inference because live bovine animals were GST-exempt. Computer-generated invoices and thumb impressions on cash vouchers, without material proving non-genuineness, were insufficient grounds for disallowance. The purchase disallowance was deleted.

Revision under Section 263 is available where an assessment order is both erroneous and prejudicial to Revenue interests, including where required inquiries or verification were not undertaken. A general request for TDS details and ledger extracts does not establish a conscious examination of substantial commission or brokerage expenditure, the reason for non-deduction of tax, or whether the payment was commission, discount, or another arrangement. Verification may require examination of franchise agreements, invoices, accounting treatment, retention terms, and applicable TDS obligations. Absence of this material inquiry supports setting aside the assessment for fresh examination while leaving ultimate taxability open.

Claimed Form 3CD reporting errors require factual verification against underlying records before a corresponding addition is sustained; the asserted duplication or typographical inflation of an ESI amount therefore remains for Assessing Officer verification. Employee PF/ESI contributions are distinct from employer contributions and are deductible only when deposited within the due dates under the relevant welfare laws. Payment before the income-tax return filing due date does not cure a delay for employee contributions. Accordingly, contributions paid after the statutory due dates are non-deductible for Assessment Year 2020-21.

Penalty proceedings under Section 271AAB require a notice under Section 274 to specify the precise statutory charge, including the applicable clause under Section 271AAB and the related penalty exposure. A notice merely referring to undisclosed income found in a search and proposing penalty under Section 271AAB, without identifying whether clause (a), (b), or (c) applies or stating the relevant conditions, does not provide a meaningful opportunity to respond and breaches natural justice. Such defective notices are invalid; consequently, the associated penalty cannot be sustained.

Unsecured corporate loans supported by lender confirmations, income-tax returns, financial statements and bank records satisfy the assessee's initial Section 68 burden on identity, creditworthiness and genuineness. Additions cannot rest solely on Investigation Wing information or a retracted accommodation-entry statement where no independent lender verification or contrary material exists. A lender's later striking off does not negate loans advanced and repaid when it was active. The second proviso's source-of-source requirement applies only from assessment year 2023-24 and did not govern the years concerned; the loans were satisfactorily explained.

Section 68 applies only to sums credited in the books during the relevant previous year. Unsecured loans received in an earlier year and carried as opening balances therefore cannot be treated as cash credits for that year. Banking-channel receipts, interest payments after tax deduction, and proof of the loans supported the assessee's explanation; unverified Investigation Wing information did not justify the addition. The Section 68 addition was consequently unsustainable and deleted.

The restriction on eligible-unit deductions for transfer-pricing adjustments applies where tax authorities enhance income through an arm's-length-price determination, not where the taxpayer voluntarily computes and returns the adjustment as business income. Exempt-income expenditure cannot be disallowed on an ad hoc basis where investments have no opening or closing balance, own funds are sufficient, and no related expenditure is identified. Foreign-exchange fluctuation loss recognised at the balance-sheet date is allowable business expenditure. For captive ITeS transactions, comparables may be excluded when functionally dissimilar, lacking reliable segmental data, or failing related-party-transaction or employee-cost filters; prior functional analysis may be followed where material facts remain unchanged.

Section 80P(2)(d) allows a co-operative society to deduct interest or dividend income earned from investments with another co-operative society. A co-operative bank continues to qualify as a co-operative society for this purpose. Section 80P(4) restricts a co-operative bank's own eligibility for deduction; it does not prevent another co-operative society from claiming deduction on interest received from investments with that bank. Interest income from investments with co-operative banks is therefore eligible for deduction under section 80P(2)(d).

Reassessment under Sections 147 and 148A(d) cannot duplicate identical additions from an original assessment when those additions have already been adjudicated on merits by the first appellate authority and remain under examination in pending tax appeals. A precedent allowing reopening after annulment of an assessment solely on a technical ground does not apply where the appellate decision also addresses the merits. The doctrine of merger and the bar against parallel proceedings preclude a second assessment process on unchanged additions. Reassessment in these circumstances is legally impermissible.

Interest earned on funds provided by the Government is not assessable as the recipient entity's income where legal ownership of that interest remains with the Government, regardless of its earlier tax treatment. A signature bonus received on transferring developed power projects constitutes taxable business revenue when it arises from the ordinary activity of developing and transferring those projects. Such consideration is not a capital receipt where it does not compensate for the extinction or sterilisation of an income-producing source, particularly when related development expenditure has been claimed as revenue expenditure.

Form No. 10B accepted after the return is filed but before the extended return-filing deadline satisfies the audit-report requirement for charitable exemption where the report was obtained and uploaded on the filing date. The audit requirement is substantive, while the timing and electronic mode of portal acceptance are procedural; a one-day acceptance delay should not defeat exemption. Relief under Section 119(2)(b) is an additional, not mandatory, remedy, and its circular-based time limit cannot displace entitlement based on substantial compliance. Availability of an appellate remedy does not bar relief where validation occurs within the extended filing period.

Deletion of an addition for alleged unaccounted foreign-bank deposits is supportable where concurrent factual findings establish that the credited amount was transferred from funds already held in another foreign-bank account, rather than constituting a fresh deposit in the relevant year. In the absence of cogent material disproving the explained source, an addition resting solely on presumption lacks factual basis. Such fact-bound findings do not ordinarily raise a substantial question of law in a further appeal.