Cash deposits were treated as explained where bank statements substantiated the mother-in-law's withdrawals, the preceding bank credit arose from a land-sale agreement, and the amount was returned by cheque on the same day. The remaining deposit was supported as a gift from the wife, a regular income-tax return filer. No material established that the repayment was undisclosed on-money for a later property purchase. Accordingly, the deposits' source and genuineness were established, and the addition for unexplained investment based on surmises and conjectures was deleted.

Third-party diary notings lacking dates, the taxpayer's name, and corroboration do not substantiate unexplained-expenditure or election-expenditure additions. Deleting an alleged payment entry while introducing a separate stamp-paper-purchase addition without an enhancement notice raises a distinct procedural defect. Where the taxpayer neither admits election expenditure nor independent material supports it, the addition lacks an evidentiary basis. On these facts, the combined additions were treated as unsustainable and deleted.

Penalty under Section 271(1)(c) requires satisfaction on concealment or inaccurate particulars to be recorded during the original assessment proceedings. Where no satisfaction was recorded for particular disallowances, a later endorsement in a giving-effect order cannot validate penalty; penalties on those additions were therefore unsustainable. Foreign-exchange loss accounted for under Accounting Standard-11 need not form part of inventory cost under Accounting Standard-2 where a recognised contrary view exists. As the resulting closing-stock valuation issue was debatable, the treatment did not establish inaccurate particulars, making the related penalty unsustainable.

Supplier confirmations and account copies supplied in remand proceedings can cure an addition based on non-response to verification notices. Under mercantile accounting, expenses accrued during the year and constituting ascertained liabilities remain deductible although paid later. Sales tax already taxed cannot be added again, VAT not debited to the profit and loss account does not support disallowance, and contractual commission is not a statutory payment subject to Section 43B. Salary additions require comparable market-price material rather than estimates based only on prior-year payments. Disallowance of expenditure related to exempt income cannot exceed the exempt income earned.

Section 68 applies only to a sum credited in the assessee's books; a documented share-trading loss recorded as a debit cannot be assessed as unexplained cash credit. Exchange-traded transactions supported by broker records, demat entries and banking channels remain eligible for set-off against long-term capital gain unless evidence establishes non-genuineness, including price rigging. An estimated brokerage-commission addition lacks basis where share dealings occurred directly through brokers and the purchase and sale transactions are substantiated.

Section 153C jurisdiction requires the Assessing Officer having jurisdiction over the searched person to record satisfaction before proceedings may be initiated against another person. A common satisfaction note is insufficient where it neither identifies seized material relating to that person nor establishes that the searched person's Assessing Officer recorded the required satisfaction. Assessment for AY 2010-11 also falls outside the applicable ten-year block period under either relevant trigger date, leaving the assessment without valid jurisdiction.

Section 80IB(10)'s post-1 April 2005 requirements for timely completion of a housing project and a local-authority completion certificate apply prospectively. Conditions inseparably connected with project approval cannot impose a later completion-certificate requirement on projects approved before the amendment took effect. Housing projects approved before 1 April 2005 remain governed by the deduction conditions applicable on their approval date and are not disqualified solely for lacking the subsequently introduced completion certificate.

Cash deposits during the demonetisation period arising from recorded cash sales of disclosed stock are not unexplained cash credits where the underlying records remain unchallenged. An addition under Sections 68 and 115BBE requires a sustainable basis to reject the stated source. Audited books, stock tallies, purchase and sales registers, cash books and VAT returns supported the availability and sale of stock, while no defects or manipulation were established and the books were not rejected under Section 145(3). Mere variation in cash-sale percentages does not prove bogus sales. Treating the cash realisation as unexplained after accepting the recorded sales would result in double taxation.

Rule 46A permits additional evidence before the first appellate authority where the Assessing Officer receives an opportunity to examine it and comment; continued non-response after repeated reminders does not indefinitely prevent disposal of the appeal. Deemed-dividend treatment requires the recipient to be a beneficial shareholder holding at least 10% voting power, and a 0.23% holding, coupled with no supporting evidence of a loan or advance, precludes that treatment. Reassessment may be based on fresh material obtained in proceedings concerning a group concern; where reopening does not reappraise material examined originally, it is not a change of opinion and the reason-to-believe condition is met. The deemed-dividend deletion remains effective, while reassessment is valid.

Section 115O levies additional income tax on an Indian domestic company when it declares, distributes or pays dividends. The tax is charged at the rate prescribed for the company under that provision, rather than at the rate applicable to a German resident shareholder under the India-Germany DTAA. Article 10, governing dividend taxation, does not displace Section 115O because treaty protection for this company-level levy applies only where the contracting states expressly extend it. Accordingly, distributed profits remain subject to the Section 115O rate.

First proviso to section 149(1) restricts reassessment notices for assessment years up to AY 2021-22 if, under the former limitation regime, a notice could no longer have been issued. For AY 2015-16, the former six-year period expired on 31 March 2022; therefore, a section 148 notice issued on 6 April 2022 was time-barred. The exclusions and minimum-period rules for section 148A proceedings affect the limitation under section 149(1), but do not extend the separate restriction imposed by the first proviso. Consequently, the reassessment proceedings and resulting additions were invalid.

Section 149(1)'s first proviso preserves the former reassessment limitation for assessment years up to AY 2021-22. For those years, a notice under the amended reassessment regime may issue only if the six-year period available under the earlier law had not expired. The extended ten-year period cannot operate retrospectively to revive reassessment proceedings already barred by limitation. Accordingly, for AY 2015-16, a reassessment notice issued on 7 April 2022 beyond the six-year period was invalid, and the reassessment founded on it was quashed.

For reassessment notices served before 1 April 2019, the applicable nine-month limitation period excludes only the period during which a judicial stay actually remained in force. Limitation resumes when the stay is vacated, not when the vacation order is communicated. Where more than sixty days remain after vacation, the statutory minimum sixty-day extension does not apply. On this calculation, the limitation expired before the reassessment order was made; administrative notifications did not extend the deadline, and the order was time-barred and quashed.

For unabated assessments under sections 153A and 153C, additions for unsecured loans, share capital and share premium require corroborated incriminating material found during search. Entries already recorded in regular books and routed through banking channels, uncorroborated retracted statements, general investigation information and post-search enquiries do not establish unexplained credits. Where confirmations, bank records and financial records supporting identity, creditworthiness and genuineness remain undisproved, suspicion cannot sustain the additions. The section 68 additions were deleted, and the related interest disallowances also failed because they rested solely on the allegation that the loans were non-genuine.

Alleged bogus purchases supported by purchase bills, delivery challans, supplier confirmations, stock records, banking payments and corresponding sales cannot be treated as wholly non-genuine merely on general sales-tax information absent transaction-specific defects. Independently confirmed purchases attract no addition; remaining disputed purchases warrant only a 5% addition for embedded profit, supported by gross-profit trends. Commission expenditure is deductible as wholly and exclusively incurred for business where confirmations, payment workings, recipients' tax records, TDS details and a nexus with sales substantiate the payments, with no cogent rebuttal. Taxable income is recomputed accordingly.

The first proviso to Section 149(1) retains the pre-amendment reassessment limitation for assessment years beginning on or before 1 April 2021. The amended regime's extended ten-year period operates prospectively and cannot revive reassessment notices already barred under the former six-year period. For assessment year 2015-16, notices issued after 1 April 2021 fall outside the applicable limitation framework. Consequently, the notice issued on 4 April 2022 was time-barred, and the related reassessment proceedings could not be sustained.

Late-filing fee under section 234F was considered unjustified where a return filed in response to a section 148 reassessment notice disclosed interest income and corresponding tax deducted at source. Absence of a return under section 139(1), by itself, did not support a routine fee when no outstanding tax liability or prejudice to the Revenue was established. The fee was accordingly set aside.

Interest paid or credited by a co-operative bank to a non-member co-operative society falls within the co-operative society exemption from tax deduction at source; the recipient's income-tax deduction eligibility does not determine the payer's obligation. Interest on specified NRE fixed deposits exempt from income tax is not chargeable in India and therefore does not attract withholding on non-resident payments. The exclusion of co-operative banks from the member-interest exemption applies prospectively, so interest on a member's deposit closed before 1 June 2015 remains outside withholding. Relief from default where a resident payee has paid tax requires verification of an accountant's Form 26A certificate.

Section 48(i) permits deduction of expenditure only where credible evidence establishes that it was incurred wholly and exclusively in connection with the property transfer. A cancellation payment made after completion of the sale was not deductible where the underlying memorandum imposed no contractual obligation to pay it on rescission and no direct transfer nexus was proved. A claimed sale commission was likewise not deductible because no concrete evidence showed that services were rendered to facilitate the transfer. Unsupported or afterthought claims cannot reduce taxable capital gains.

GSTR-3B due dates for February, March and April 2020 remain unchanged, but interest and late-fee relief applies where returns and tax are furnished within prescribed timelines. Reduced or nil interest depends on the taxpayer's preceding-year aggregate turnover and timely filing; non-compliance attracts regular interest, late fee and potential penalty from the original due date. Late-fee waivers also apply to specified GSTR-1 filings. Input tax credit restriction under rule 36(4) is deferred for February through August 2020 and must be applied cumulatively in the September 2020 return. Specified returns, statements, e-way bills and statutory compliance periods receive separate extensions.