Section 148 reassessment limitation permits only the time surviving from an earlier reassessment notice deemed to be a show-cause notice under Section 148A(b), after excluding time for supplying material and receiving a reply. Where the surviving period is below seven days, the statutory minimum period of seven days applies. A fresh notice issued after that period, even on calculations most favourable to the Revenue, is time-barred. A later communication merely re-supplying material already furnished does not revive or restart limitation. Reassessment founded on such a notice is without jurisdiction.

Section 50C applies to transfers of tenancy rights in land or a building because the mode of holding the property does not alter its character for stamp-duty valuation purposes. Distinctions between leasehold and tenancy rights may affect the nature or value of the transferred interest, but do not exclude the transfer from the provision. Where an assessee claims that the stamp valuation exceeds fair market value and seeks a valuation reference, the statutory conditions under section 50C(2) must be examined. If satisfied, valuation by the Departmental Valuation Officer is required before determining full value of consideration.

Non-genuine purchases supported by accommodation bills cannot be added in full where the corresponding sales are accepted. Procurement through the grey market may justify an addition limited to the profit element embedded in those purchases, rather than their entire value. A 25% profit estimate lacked material support where the assessment record indicated that the relevant grey-market margin would not exceed 8%. The addition for the disputed purchases is therefore restricted to 5% of their value.

Section 14A disallowance requires factual verification where sponsorship-related expenditure is claimed and exempt-income investments exist. The expenditure must be examined to determine whether it relates exclusively to sponsorship income rather than investments producing exempt income; any adjustment is to be restricted under Rule 8D(ii). Income offered on a gross basis does not remove the need for that verification where specific expenditure has been claimed. Earlier assessments containing no disallowance do not bar examination in a later year, because each assessment year is separate and res judicata does not apply to income-tax assessments.

Where declared sale consideration for immovable property is disputed against the stamp-duty valuation, the Assessing Officer must obtain a Departmental Valuation Officer's determination of fair market value before using the stamp-duty value for capital-gains computation under Section 50C. Without that valuation reference, the stamp-duty valuation cannot replace the declared consideration in the stated circumstances.

Rectification under section 154 is confined to a mistake apparent from the record and cannot reopen a sales figure already examined and accepted during the original assessment. Where sales were verified against VAT returns and a higher return figure was treated as a typographical error, an audit objection identifying the discrepancy alone did not establish an apparent mistake or displace the prior verification. Reliance solely on that objection amounted to borrowed satisfaction rather than an independently identifiable record-based error. The rectification was invalid, and the resulting sales addition was deleted.

High-turnover, branded companies with materially different scale, brand value, operational capacity, and functions-assets-risks profile are not comparable to a captive software development service provider and should be excluded in determining the arm's-length price. Interest on delayed associated-enterprise receivables must be benchmarked by reference to the invoice currency. Where invoices are USD-denominated, LIBOR plus an appropriate mark-up, or another suitable currency-appropriate rate, applies rather than the SBI rate. The transfer-pricing computation consequently requires revised comparables and a currency-aligned interest benchmark.

Misreporting penalties require a precise charge in the penalty notice; a notice alleging only under-reporting cannot support a penalty imposed for under-reporting arising from misreporting. A deduction claim that is fully disclosed, bona fide and debatable, particularly amid conflicting judicial views, falls outside misreporting unless it is shown to meet a specified statutory category. Where the taxpayer discloses all material facts and gives a bona fide explanation, the under-reported-income exclusion applies, so a penalty founded on disallowance of that claim lacks statutory basis.

Penalty for under-reporting of income consequent on misreporting under section 270A was unsustainable where the claimed cost of improvement was disclosed in the return and supporting particulars. Disallowance based only on inadequate documentary evidence, particularly for incidental local purchases and labour payments, did not establish suppression or misrepresentation when the improvement work itself was undisputed. Contractor-level documentation was not required in those circumstances, and the penalty was quashed.

Cash deposits in a proprietary concern's bank account may be explained through reconstructed cash books, monthly sales summaries and daily sales registers where they align with declared turnover and regular deposit patterns. Customer-specific particulars for retail cash collections are not warranted in those circumstances, particularly where turnover is taxed under the presumptive-taxation scheme. The disputed deposit was consistent with normal retail sales and could not be sustained as unexplained cash credit.

Appellate authorities may entertain legitimate deductions under Sections 80C and 80CCD(1B) that were omitted from an original return and not claimed through a revised return. A taxpayer's lack of awareness should not, by itself, defeat an otherwise eligible statutory deduction. Supporting evidence of investments in notified PPF and National Pension Scheme arrangements may be admitted under Rule 29 where it is material to determining entitlement, subject to verification. Following verification of the admitted evidence, the claimed deductions are to be allowed.

Failure to substantiate the source of stamp-duty and registration payments supported an addition for unexplained investment, as the alleged loan lacked confirmation, proof of transfer, and other corroboration. A stamp-duty valuation exceeding the declared property consideration was treated as deemed income because the claimed effect of longstanding tenancy was unsupported by independent valuation evidence or proof of a lower fair market value, and no statutory valuation reference was sought. Unrebutted search material showing cash paid for the property supported a further addition as unexplained money, with no seller confirmation or reliable contrary evidence produced.

Enhanced penalty for misreporting of income under section 270A requires proof of the specific ingredients in section 270A(9), rather than mere disallowance of a deduction claim. Disclosure of the claim and payment through banking channels may demonstrate disclosure of material facts. General investigation material concerning the recipient's alleged modus operandi does not by itself establish misrepresentation, suppression of facts, or furnishing of false particulars. An inadmissible claim is distinct from misreporting of income, and penalty proceedings require an independent examination; an assessment disallowance is not conclusive. Where statutory conditions for misreporting are unproved, the enhanced penalty is unsustainable.

Contractual recruitment and training services rendered to an insurance company are business-support activities rather than services in a profession enumerated or notified under section 44AA(1). Knowledge, skill or training involved in delivering those services does not by itself make them technical consultancy or professional services. Where the provider neither conducts insurance agency business nor earns commission or brokerage, the resulting receipts are business receipts eligible for the business presumptive-tax regime, subject to its statutory conditions, rather than the regime for specified professions.

Net-profit estimation at 8% in a best-judgment assessment was unsustainable because neither that rate nor the initially adopted 12% rate rested on the taxpayer's past history or comparable businesses. Absence of accounts and non-compliance with information requests may justify estimating business profit, but the estimate must be bona fide, rational and non-capricious. Profit must be redetermined using past history or comparables after a hearing.

Automated subscription, training and support services do not constitute fees for technical services under Article 12(5)(b) of the India-Netherlands tax treaty or section 9(1)(vii) of the Income-tax Act where they merely provide access to software systems. The make-available requirement is not met when software is hosted outside India, no unrebutted evidence establishes human intervention, and the recipient receives only a standard facility and a right to use the systems. Training and support limited to system use, without transfer of underlying technology or capability for independent future application, likewise do not transfer technical knowledge, skill, know-how or processes.

Corporate insolvency proceedings give finality to claims admitted under an approved resolution plan and extinguish excluded statutory dues, preserving a clean slate for the corporate debtor or resolution applicant. Where the successor entity has entered liquidation after failure to implement the approved plan, and no departmental tax claims for earlier assessment years were admitted in either the resolution or liquidation process, those claims cannot be pursued through connected income-tax appeal proceedings.

Section 147 permits assessment of income discovered during reassessment only after the Assessing Officer assesses or reassesses the income forming the recorded basis for reopening. The expression "and also" operates cumulatively, and Explanation 3 does not remove that substantive condition. Where no addition or adverse finding is made on the share-transfer issue recorded for reopening, an unrelated addition for unexplained cash credit cannot be sustained in that reassessment. A fresh notice under Section 148 is required to pursue the unrelated income; otherwise, the reassessment is without jurisdiction and void.

Interest earned by a primary agricultural credit co-operative society on its own funds temporarily or statutorily invested with banks is attributable to its credit-facility business and qualifies for deduction under section 80P(2)(a)(i), provided the funds are not liabilities payable to members. The wider expression "attributable to" covers income having a business nexus, unlike the narrower "derived from" standard. Provisions for interest payable and audit fees are allowable business expenditure where they represent accrued, quantified liabilities connected with the business rather than contingent obligations. Taxable income requires recomputation after granting the eligible deduction and allowing those accrued liabilities.

Reassessment for alleged escaped income requires the Assessing Officer to identify the proposed addition in the notice under Section 148A(b), obtain prescribed approval, consider the taxpayer's response, and issue an order under Section 148A(d) before reopening. Where a proposed cash-deposit addition was considered and dropped after accepting the explanation, a later cash-deposit addition not identified in the notice or statutory order and lacking specified-authority approval failed to satisfy the mandatory procedure. The unsupported reassessment addition was therefore deleted.