Documentary proof of lender identity, creditworthiness and transaction genuineness, including confirmations, financial records and banking-channel receipt, interest and repayment, discharges the assessee's onus for unsecured loan credits. A general allegation that lenders are accommodation-entry providers, without material linking the assessee or transactions to that arrangement or rebutting the evidence, does not sustain additions for loan credits or repayments. Unexplained-expenditure additions for alleged interest or commission require evidence that expenditure was actually incurred; presumptions, estimates, or consequential allegations arising from loan transactions are insufficient.

Transfer-pricing analysis of banking services requires demonstrable functional, asset and risk comparability, a reliable prescribed method, and an effective opportunity to rebut third-party data obtained under section 133(6). Counter-guarantee pricing should distinguish an intermediary's role from that of a guarantor bank. Attribution of ECB interest and fee income should reflect each entity's funding, lending functions and assumption of credit, liquidity and interest-rate risks. Regional support and head-office expense charges require evidence of services received, business benefit, cost base and allocation methodology. Mark-to-market treatment of AFS and HFT investments held as stock-in-trade and consistently valued at lower of cost or market value concerns whether diminution is a trading loss rather than an unascertained-liability provision.

Timely issuance of a draft assessment order attracts the separate final-order timelines prescribed for DRP directions, notwithstanding the general assessment limitation. Tax computation must conform to assessed nil income after set-off of brought-forward losses and unabsorbed depreciation, subject to verification of year-wise utilisation. For traded goods purchased from associated enterprises and resold independently, RPM remains appropriate absent material processing, substantial value addition, or defects in gross-margin comparables; a comparable with verifiable gross-profit data cannot be rejected solely under TNMM profitability criteria. A commercially justified weighted NAV-DCF valuation may determine the arm's length price of an operating-business transfer where neither NAV nor DCF should receive exclusive weight. A transaction deemed international does not alone establish associated-enterprise status for secondary adjustment; refund eligibility requires verification of that relationship.

Section 254(2) permits rectification only of a mistake apparent from the record and does not authorise review of a concluded reassessment decision. A retrospective insertion of section 147A after an earlier decision applying the law and binding jurisdictional precedent then in force may raise a debatable legal question, particularly while its constitutional validity remains under challenge. Retrospective operation alone therefore does not establish an apparent mistake or support recall or modification of the earlier decision.

The first proviso to Section 149(1) retains the earlier limitation regime for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, a Section 148 notice issued on or after 1 April 2022 is barred by limitation. Service of a Section 148A(b) notice within the earlier limitation period does not preserve or extend time for the later Section 148 notice. A time-barred Section 148 notice invalidates the consequential reassessment proceedings and assessment order.

Section 69A cash-deposit explanations require a demonstrable link between cash sales, cash-in-hand and individual bank deposits. Matching aggregate turnover reported in returns and VAT records, particularly where multiple accounts are used, does not alone establish that nexus; cash books, sales records, stock records or a reconciliation may be needed for factual verification. A Rule 46A objection does not arise without a demonstrated breach, but absence of that breach does not remove the need to verify the stated source. Section 148A(b) requires at least seven days to respond; despite a shorter stated deadline, twelve days before the Section 148A(d) order provided a real opportunity where no response attempt or impediment was shown.

The first proviso to Section 149(1)(b) preserves the earlier six-year limitation for reassessment notices relating to covered assessment years and operates as an absolute restriction. For Assessment Year 2015-16, that period expired on 31 March 2022; therefore, a notice issued on 12 April 2022 was time-barred. The fifth and sixth provisos, which govern exclusions or extensions when computing the amended limitation periods, cannot enlarge the restriction retained by the first proviso. A time-barred jurisdictional notice invalidates the consequential reassessment. Medical incapacity of the person handling an assessee's legal affairs may constitute sufficient cause for condoning filing delay.

Failure to record satisfaction for penalty for an alleged cash-transaction contravention does not, by itself, make an assessment erroneous and prejudicial to the Revenue. The penalty operates independently of income computation and, for the relevant year, fell within the Joint Commissioner's competence rather than the assessment process. Revision cannot create a fresh basis for, or bypass the separate limitation governing, penalty proceedings. Where the underlying cash transactions remain disputed and the restriction's applicability is uncertain amid divergent judicial views, non-initiation represents a plausible legal view. Revision jurisdiction therefore cannot be invoked to initiate or revive independent penalty proceedings.

Interest earned by a co-operative credit society on deposits of business funds with co-operative or other banks qualifies for deduction under Section 80P(2)(a)(i) where those deposits are connected with its regulated lending operations. Funds generated through the business of providing credit facilities to members retain their business-income character when deposited with banks. The principle concerning retention and investment of members' sale proceeds does not apply to interest on the society's own business funds, so the related addition is deleted.

Rectification jurisdiction is limited to an obvious, patent and self-evident mistake apparent from the record and cannot be used to reopen a concluded merits determination through fresh arguments. Unsigned and blank notices issued under Section 143(2) require authentication under Section 282A(1). Section 292BC, which concerns electronically granted approvals by income-tax authorities, does not dispense with authentication requirements for notices or other communications issued to an assessee. Accordingly, it cannot validate an unauthenticated statutory notice or support review under the guise of rectification.

Purchase of 99-year leasehold rights in land does not attract Section 56(2)(x) of the Income-tax Act, 1961, which taxes receipt of immovable property for consideration below its stamp-duty value. The assessee-favourable interpretation applied to the analogous deeming provision for leasehold rights was followed because no contrary jurisdictional High Court or Supreme Court decision existed. As the transaction involved transfer of leasehold rights with the lessor authority's permission, the stamp-duty-value-based addition was deleted.

Reassessment requires a reason to believe based on tangible material and cannot review a completed scrutiny assessment merely through a change of opinion. Incorrect transaction details, mechanical reliance on investigation inputs or a retracted third-party statement, and failure to consider evidence previously examined undermine reassessment jurisdiction. Recorded equity-share purchases supported by stock-exchange, broker, bank and source-of-funds records cannot be treated as unexplained investment where the source is explained. Equity-share sale proceeds already recorded in the books and offered to tax constitute sale receipts, not unexplained investment; taxing them again as unexplained amounts results in double taxation.

Section 56(2)(viib) taxes share consideration received above the fair market value of unquoted shares. Rule 11UA(2) permits the taxpayer to choose either the Net Asset Value method or the Discounted Cash Flow method supported by a merchant banker's valuation report. Although the Assessing Officer may examine the valuation methodology and underlying data, the chosen Discounted Cash Flow method cannot be substituted with Net Asset Value without establishing grave or material errors, incorrect facts, or a flawed valuation basis. Rejecting projections as unreasonable without examining their basis is insufficient; the Discounted Cash Flow valuation was accepted and the addition deleted.

Section 69A applies only to money owned by the assessee. Where an angadia intermediary handles third-party cash as a commission-based facilitator, gross transit funds cannot be treated as unexplained money merely because beneficiaries are unidentified, absent evidence of retained funds or corresponding assets or investments. Taxability is confined to the embedded commission income. Commission must be estimated on a commercially reasonable basis reflecting the high-volume, low-margin nature of the business; 0.30% of unaccounted turnover is considered appropriate, with credit for commission already assessed. Such income is taxable at normal rates rather than under Section 115BBE.

Condonation of delay under Section 5 of the Limitation Act requires a satisfactory, pleaded explanation establishing sufficient cause. Earlier filing before a court without territorial jurisdiction and administrative movement of records do not, by themselves, justify prolonged delay. A COVID-19 ground not pleaded in the supporting affidavit cannot support condonation. Negligence, inaction, and lack of bona fides are inconsistent with sufficient cause.

Pending reassessment proceedings initiated under Sections 148A(3) and 148 were not examined on merits in writ jurisdiction because the impugned order was only a prima facie determination capable of reconsideration on material furnished during the proceedings. Statutory remedies would remain available if an adverse order followed, while the objection concerning prior sanction remained open before the competent authority. The writ petition was disposed of with all contentions left open.

Deemed timely payment under the Income Declaration Scheme applies where payment by cheque, RTGS or electronic transfer was tendered by 03.10.2017 and credited by the bank by 05.10.2017, treating it as paid by the 30.09.2017 due date. Eligibility for this benefit depends on verification of the cheque tender date and bank credit date. The authority must verify those factual prerequisites and extend the Scheme's benefit if the circular's conditions are met.

Reassessment for AY 2020-21 cannot be initiated solely from information about a land-sale transaction completed in FY 2020-21, because that transaction pertains to AY 2021-22. Where the recorded information, the order under section 148A(3), and the Revenue's affidavit identify the transaction as occurring in FY 2020-21, they provide no basis to infer escaped income for AY 2020-21. The statutory precondition for reopening is therefore absent, rendering the reassessment proceedings invalid and liable to be quashed.

Reassessment proceedings under Sections 147, 148 and 148A require meaningful consideration of an assessee's explanation of bank credits before determining whether reassessment is warranted. Where credits are claimed to include advances and the assessee provides entity details while offering further confirmations and supporting particulars, the tax authority must afford an opportunity to furnish that material. Proceeding without seeking or considering the offered confirmations and clarifications does not adequately assess the fitness of the matter for reassessment.

CBDT instructions and office memoranda standardise recovery or refund adjustment at 20% of the disputed demand as the condition for stay while a first appeal remains pending. Where aggregate payments and refund adjustments exceed that threshold despite a pending appeal, stay application and stay order, recovery must be confined to 20%. Amounts recovered or adjusted above that limit require refund, with the identified excess directed to be returned within four weeks.