Deductibility of common expenditure against taxable non-member receipts of a mutual concern - Rental income from terrace space for cellular tower - income from house property Validity of jurisdictional scrutiny notice alleged to be inconsistent with CBDT instruction - Challenge to the validity of the jurisdictional scrutiny notice on the ground of non-compliance with the CBDT instruction - HELD THAT: - The assessee conceded that the additional ground was covered against it by the cited Specia... ... ...

TP Adjustment - TNMM comparability analysis based on audited annual accounts - Working capital adjustment to net profit margins - Employees' provident fund contribution-statutory due date for deduction TNMM comparability analysis based on audited annual accounts - Working capital adjustment to net profit margins - Determination of arm's length price for international transactions involving healthcare imaging equipment and related transactions under TNMM, on recomputation of comparable... ... ...

Addition u/s 68 - share capital and share premium - Discharge of initial onus by documentary evidence - Identity, creditworthiness and genuineness of share subscriber HELD THAT: - The assessee produced its books and bank records and the subscriber's PAN, address, bank statement and audited financial statements. The source of the subscriber's investments had also been explained in its assessment. This material discharged the assessee's initial onus; reliance solely on an investigat... ... ...

Exemption u/s 11 for maritime education and training - Educational purpose vis-a -vis general public utility Eligibility of a society providing marine engineering education and training to seafarers for exemption u/s 11, notwithstanding the objection that its objects were of general public utility - HELD THAT: - The Tribunal found that its earlier decision [2025 (12) TMI 1224 - ITAT MUMBAI] had categorically held the assessee to exist solely for imparting education. As no difference in the fa... ... ...

Profit-element addition on unverifiable purchases where sales are accepted - Validity of reassessment based on transaction-specific investigation information - Authority of Jurisdictional Assessing Officer to issue reassessment notice - Effect of exception to monetary limits for departmental appeals Validity of reassessment based on transaction-specific investigation information - Validity of reassessment of a steel trader on information concerning purchases from an alleged accommodation-bill... ... ...

Reassessment beyond four years after scrutiny assessment - Failure to disclose fully and truly material facts Validity of reassessment for assessment year 2012-13 initiated after four years from the end of the assessment year following an assessment under section 143(3), without an allegation of failure to make a full and true disclosure of material facts - HELD THAT: - The assessee had furnished complete particulars regarding the sale of shares during the original scrutiny assessment. The re... ... ...

Reassessment approval - application of mind - Alleged bogus raw-material purchases - uncorroborated third-party statement Change of opinion in reassessment - Subsequent tangible material - Reassessment based on information subsequently received concerning the supplier's alleged accommodation-entry activities - HELD THAT: - Though the assessee had disclosed purchases from the supplier in the original assessment, the subsequent information based on the supplier's statement that it was p... ... ...

Revision under section 263 - plausible view after enquiry - Interest on enhanced compensation - exemption for compulsorily acquired agricultural land Revision under section 263 of an assessment allowing exemption for interest received under section 28 of the Land Acquisition Act on compulsory acquisition of agricultural land - HELD THAT: - The assessment record showed that the Assessing Officer had specifically sought details and justification for the claimed exemption, considered the assesse... ... ...

Third-party loose sheet-nexus with assessee - Unexplained expenditure - proof of actual incurrence - Presumption on documents seized from third party - Unexplained money-proof of ownership Third-party loose sheet-corroborative nexus - Unexplained expenditure-proof of actual incurrence - Presumption on documents seized from third party - Sustainability of addition for unexplained expenditure on the basis of a loose sheet seized from a third party and that person's search statement - HELD T... ... ...

Third-party electronic records and retracted statements as evidentiary basis for additions - Estimated unaccounted cash receipts from residential flat sales Evidentiary value of third-party electronic records - Retracted statements u/s 132(4) - Unexplained investment in alleged cash loans under section 69 - HELD THAT: - The statutory presumptions arising from possession of seized material are rebuttable and cannot be mechanically extended to an assessee merely because it is referred to in ele... ... ...

Unexplained cash credits - unsecured loan transactions - Unexplained expenditure-loan-related interest and professional charges - Interest on borrowed capital-sufficient interest-free funds - Borrowing-related expenditure-ad hoc proportionate disallowance - Disallowance of expenditure relating to exempt income-Rule 8D - Form 26AS receipts-reconciliation with recorded income - Refinancing of business borrowings-allowability of interest and loan-processing charges Unexplained cash credits - uns... ... ...

Offshore supply receipts - taxability in India - Artificial splitting of turnkey contracts - Fixed place and dependent agent permanent establishment - Presumptive taxation of turnkey power projects Offshore supply receipts - Artificial splitting of turnkey contracts - Transfer of title under CIF terms - Taxability in India of offshore-supply receipts under a three-contract transmission project arrangement, including the alleged artificial splitting of the contract and transfer of title under ... ... ...

Jurisdiction under section 153C - satisfaction note linking seized material to assessment years - assessment year-wise nexus of incriminating material - Assumption of jurisdiction under section 153C for assessments based on a seized hard disk without identifying the assessment years to which the incriminating material related - HELD THAT: - The satisfaction note merely recorded seizure of a hard disk and initiation of proceedings for the stated assessment years, without recording how the mate... ... ...

Modified return following business reorganisation - scope of section 170A(2)(a) - Transfer-pricing proceedings - validity dependent on pending scrutiny assessment - Writ jurisdiction-challenge to assumption of statutory authority Modified return following business reorganisation-scope of section 170A(2)(a) - Validity of fresh scrutiny of a modified return furnished after business reorganisation where the original assessment stood completed and no assessment proceedings were pending - HELD THA... ... ...

Computation of claim of deduction u/s 10B - depreciation on @60% on computer accessories Computation of claim of deduction u/s 10B - payment of Senior Management Salary, which has been allocated by the Assessing Officer in the ratio of turnover of EOU and non-EOU units as against Appellant's allocation of 5% of total expense - ITAT held no merit in the action of the Assessing Officer in reducing the claim of deduction u/s 10B - HELD THAT:- This Court does not find any question of law which a... ... ...

Limitation for assessment u/ss 153A and 153C - limitation computed from the assessment year in which the satisfaction note was recorded HELD THAT: - Since the satisfaction note was recorded in AY 2022-23, the applicable ten-year period, reckoned backwards from that year, extended only up to AY 2013-14. The assessment for AY 2010-11 was therefore beyond limitation so also in light of Ojjus Medicare Pvt. Ltd. [2024 (4) TMI 268 - DELHI HIGH COURT].. [Paras 6, 7] The assessment order was held ... ... ...

Revisional jurisdiction u/s 263 - erroneous and prejudicial assessment orderRevision of reassessment based on information already examined by AO - Distinction between lack of inquiry and inadequate inquiry Validity of revision of the reassessment order concerning alleged accommodation-entry transactions, where the Assessing Officer had examined the same Insight Portal information - HELD THAT: - Revisional jurisdiction requires the assessment order to be both erroneous and prejudicial to the i... ... ...

Non-application of mind in revision proceedings - Reasoned order on rectification application Non-application of mind in revision proceedings - Revision of the income-tax intimation - failure to consider expenditure disclosed in the return - HELD THAT: - The computation was confined to the receipts and the claimed exemption, while the expenditure disclosed in the return was entirely overlooked. The revision authority likewise ignored this material aspect, although it went to the root of the c... ... ...

Reassessment based on unverified audit objection - Commercial expediency of interest on borrowed funds invested in subsidiary Reassessment based on unverified audit objection - Non-application of mind - Validity of reassessment initiation founded on an alleged deduction of health and education cess which the assessee had not claimed - HELD THAT: - The assessee had categorically asserted that no deduction of health and education cess had been claimed. The Assessing Officer issued the notice wi... ... ...

Unexplained cash credit - sale proceeds of unlisted equity shares - Substantial question of law - interference with findings of fact Unexplained cash credit - sale proceeds of unlisted equity shares - Test of human probabilities - Addition as unexplained cash credit in respect of sale proceeds received on sale of unlisted equity shares - HELD THAT: - The nature and source of a credit must be tested on the entirety of the evidence. While surrounding circumstances and the test of human probabil... ... ...