Unrebutted valuation findings confirming that declared property sale and purchase values matched fair market value preclude unexplained-money additions under section 69A; the additions were deleted. Failure to obtain an audit attracts penalty under section 271B where taxpayers neither plead nor establish reasonable cause arising from circumstances beyond their control; the penalties remained intact. The valuation determination therefore governs the property-value issue, whereas the absence of proved reasonable cause sustains the audit-default penalties.

Regulatory stock-exchange charges arising from delivery, reporting, deposit, margin and client-code lapses are compensatory rather than expenditure for an offence or a purpose prohibited by law. Their description as penalties or fines in a tax-audit report does not change that character, so they remain allowable business expenditure. A health and education cess deduction claimed with full disclosure under the then-prevailing judicial interpretation does not constitute under-reporting or misreporting merely because a later retrospective amendment disallows the claim. No penalty arises for such a bona fide disclosed claim.

Penalty for contravening section 269SS requires specific findings that the taxpayer accepted a loan, deposit, or specified sum in cash from an identifiable person and that the applicable monetary threshold was met. Penalty provisions are strictly construed, and the burden under section 273B arises only after these foundational requirements are established. Cash deposits in a bank account, or rejection of an explanation for their source in assessment proceedings, do not alone prove acceptance of a prohibited loan, deposit, or specified sum. Without evidence identifying the counterparty and transaction character, penalty under section 271D cannot be sustained.

Approved engineer valuation reports support a claimed cost of improvement where construction is undisputed, the report shows no defect, and no contrary valuation material exists. Tax authorities should not replace such a report with unsupported per-square-foot estimates or plinth-area rates without a technical basis or alternative valuation. Long-term capital gains should therefore include the substantiated improvement cost. By contrast, interior expenditure lacking bills, vouchers, or other supporting material does not qualify for the Section 54F deduction.

Penalty for concealment under section 271(1)(c) applies where an assessee knowingly claims inadmissible Chapter VI-A deductions in a revised return, thereby seeking an improper refund. Disclosure of correct income only after detection in survey proceedings and issuance of a reassessment notice supports a finding of conscious concealment. Reliance on allegedly incorrect advice from a tax consultant does not rebut that finding where the assessee was aware that the deductions were not allowable. The concealment penalty was therefore sustained.

Section 275(1)(c) requires a concealment-penalty order to be made by the later of the end of the relevant financial year or six months from the month in which penalty proceedings begin. Where proceedings began through an assessment order in September 2024, the six-month period ended on 31 March 2025. A penalty order made on 17 April 2025 was therefore time-barred, requiring deletion of the concealment penalty.

Section 69A does not apply to cash deposits arising from cash sales that are recorded in the books of account. Where the books remain unrejected and the related purchases, stock position, and sales are not disputed, the deposits cannot be treated as unexplained money. As the cash sales were already disclosed as income, deletion of the addition is sustained.

Assignable contractual rights, including rights reinforced by a specific-performance decree to obtain conveyance of immovable property, are property and capital assets. Their assignment for consideration is a transfer taxable as capital gains rather than income from other sources, even where title or possession has not passed. Claims for indexed cost of improvement and residential-investment exemption require verification of supporting records and fresh adjudication. In alleged penny-stock share sales, surrounding circumstances may, on a preponderance-of-probabilities assessment, displace banking and demat documentation and require the taxpayer to establish genuineness. Unusual off-market acquisition, abnormal market movement and lack of credible investment rationale supported treatment of proceeds as unexplained cash credit.

Domestic enforcement of the MFN clause requires a notification under section 90(1). The notification modifying Article 11(2) of the India-Netherlands DTAA reduced source taxation of interest for beneficial owners but did not incorporate the exemption for government-approved debt claims in the India-USA DTAA or a comparable India-Italy DTAA exemption. In the absence of a specific notification extending a nil rate, interest on income-tax refunds under section 244A remains taxable at 10% under Article 11(2) of the India-Netherlands DTAA.

Interest earned by a co-operative credit society on temporary deposits of funds not immediately required for lending to members is attributable to its business of providing credit facilities. Such interest qualifies for deduction under Section 80P(2)(a)(i) where the deposits represent the society's own deployable funds rather than amounts retained for, or payable to, members. The separate deduction applicable to investments with another co-operative society does not govern this position. Interest on bank deposits was therefore treated as qualifying business income, requiring deletion of the addition made for non-qualifying income.

Section 54B exemption for reinvestment in agricultural land was allowable where a co-owner's identical claim, based on the same sale and reinvestment, had been accepted in reassessment; the corresponding claim could not be denied for either assessment year. Agricultural income could not be newly assessed as income from other sources at appellate stage where the original assessment had not addressed that taxability and no notice of enhancement under section 251(2) was issued. The additions were unsustainable and excluded from taxable income.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the Revenue. Enquiries into trademark acquisition, capitalisation and depreciation, including supporting bills, financial statements and explanations, may support a plausible assessment view without a mandatory valuation report. The distinction between absence of enquiry and inadequate enquiry remains material despite Explanation 2(a); a revisionary authority cannot replace the Assessing Officer's plausible view or order fishing and roving verification merely because further enquiry appears desirable. As these conditions were not established, the revisionary order was quashed and the original assessment restored.

Bank-account attachment pending a restored statutory appeal should be replaced by proportionate security where the appeal has been remitted for fresh decision and remains undecided. Revenue protection is achieved by requiring deposit of 20% of the assessed tax liability within three weeks, after which the accounts must be released. The restored appeal is to receive priority disposal within six months.

Section 69A applies only where the taxpayer does not satisfactorily explain the nature and source of money. Cash deposited during demonetisation was explained as business cash, including advances returned by paddy-procurement agents, supported by cash books, financial statements, agent details and comparative deposit data. As the books were not rejected and available evidence supported the business practice, the source was treated as satisfactorily explained. No addition for unexplained cash deposits was warranted, and the factual finding raised no substantial question of law under Section 260A.

Agricultural treatment of social forestry losses depends on basic agricultural operations on land and operations integrally connected with them. Seed-route cultivation of saplings on land, including consequential pot or polybag operations, is agricultural; landless clonal propagation and post-sale supervision of farmers' trees are business activities for raw-material procurement. The agricultural-loss disallowance, including depreciation, and the corresponding Section 115JB book-profit adjustment were confined to the land-based component. Concealment penalty does not arise where the impugned addition leaves tax liability unchanged under the book-profit regime, because no tax has been sought to be avoided.

Non-resident income is chargeable in India only when received, accrued, arisen, or deemed to accrue or arise there; payer residence or deduction claims alone do not establish situs without a real nexus to the income-producing right or activity. Advance-ruling jurisdiction is confined to the applicant, the stated transaction and incidental questions, and tax-avoidance findings require an identifiable Indian tax incidence. Extended reassessment limitation requires a qualifying asset, transaction or entry belonging to the assessee and disclosure enabling a response. Protective assessment may resolve uncertainty over the correct assessee, but does not authorise protective recovery or indefinite withholding of TDS refunds.

Section 147's Explanation permits a pending reassessment to cover any further escaped-income issue noticed during those proceedings without initiating a fresh Section 148A process. Its scope is not confined to information available at commencement or derived from the original reassessment material, and it applies even if the original issue produces no addition. The omission of "and also" from the amended provision distinguishes precedent based on the earlier wording. Search-derived and other external material may therefore enlarge the pending reassessment, while the search-assessment mechanism remains an alternative route. Plain statutory language in an Explanation can expand the main provision where it clearly conveys that legislative intent.

Refunds arising from TDS assessments and appellate give-effect orders constitute crystallised rights and are not contingent on the pre-assessment processing mechanism for TDS statements or furnishing Form 26B. Section 201 governs TDS assessment, while Section 200A and Rule 31A regulate statement processing and adjustments before assessment. Where give-effect orders are already on departmental record and no refund adjustment order exists under Section 245, refunds cannot be withheld on procedural grounds. Applicable interest remains payable under Section 244A until payment.

Production of income-tax search records under Section 91 CrPC requires a continuing showing that the documents are necessary or desirable at the relevant stage; prior judicial scrutiny of the authorisation and search does not create a general right to repeated disclosure of confidential foundational material. Further production was therefore declined. Recall of a witness under Section 311 CrPC likewise requires that additional examination be essential to a just decision. Where the proposed confrontation depended solely on an unavailable document and the witness had already been substantially cross-examined on the search and recovery, recall was not essential. The procedural orders remained undisturbed, without determining the criminal charges.

Final settlement orders under the income-tax settlement scheme attain statutory finality for matters they cover, including deductions reflected in total income. Once a settlement application proceeds, exclusive jurisdiction over the relevant return and assessment year lies with the Settlement Commission. The Assessing Officer cannot reopen such settled matters through reassessment provisions. Allegations of fraud or misrepresentation must be pursued through the settlement scheme's prescribed mechanism rather than reassessment; rejection of that remedy leaves the final settlement order effective. Revenue authorities may participate in settlement proceedings and place relevant material before the Settlement Commission.