Private Indian-registered vehicles carrying only passenger luggage fall within the private-conveyance regime under Section 43(1), which does not require commercial cargo reporting or a Section 51 export-clearance order. Placement of such a vehicle in a maritime container for safe transit does not convert it into commercial export cargo. Accordingly, re-import duty exemption cannot be refused merely because no Section 51 clearance was obtained on departure. Where electronic Bill of Entry filing requires an IEC or GSTIN that a personal vehicle owner cannot possess, the statutory alternative permitting filing in another manner applies. Customs must accept manual filing and release the vehicle on the required bond.

The provisos to section 56(2)(vii)(b) permit use of the stamp-duty value on an earlier agreement date only where that agreement fixes consideration for the same immovable property ultimately transferred and consideration, wholly or partly, is paid through a non-cash mode on or before that date. A booking agreement for a different old-building flat, with separate consideration, did not establish either requirement for the redeveloped flat registered later. As no prior agreement fixed the registered consideration for the transferred property, and no legally established payment linkage was shown, the concessional valuation date was unavailable. The addition for excess stamp-duty value over registered consideration was sustained.

Section 250(6) requires appellate orders to identify issues, decisions and reasons. Sending hearing notices to an email address other than the one supplied in the appeal form, coupled with an ex parte assessment, justified restoration for fresh adjudication after an effective hearing. Under section 272A(1)(d), non-compliance with a notice under section 143(2) and the first notice under section 142(1) constituted separate defaults. Successive section 142(1) notices concerning similar issues constituted one continuing default rather than separate penal defaults. Penalty liability was accordingly confined to the two distinct defaults, and penalties for the remaining successive notices were deleted.

Interest on refinanced borrowings qualifies for deduction under Section 24(b) where the original borrowing funded construction of let-out house property and a direct, verified nexus between the original loan and refinancing is established. Consistent treatment in earlier assessments supports the claim unless the use or nature of funds has changed. Section 14A disallowance cannot apply where no exempt income was earned, notwithstanding investments capable of generating such income. Interest attributable to borrowings used for investment may be capitalised if the actual deployment of funds and related interest allocation are verified.

Jurisdiction to impose penalties under Section 271D rests with the competent prescribed authority. The Standard Operating Procedure operationalising Penalty Units for Chapter XXI penalties ended the transitional arrangement under the Faceless Penalty Scheme, 2021, which had allowed an Assessment Unit to act as a Penalty Unit. Once Penalty Units became operational, an Assessment Unit could no longer issue a penalty order under Section 271D. A penalty imposed thereafter by an Assessment Unit was without jurisdiction and liable to be quashed.

Penalty notices under sections 271(1)(c) and 271AAB(1A) must identify the exact charge or statutory clause invoked. Retaining both concealment and inaccurate-particulars limbs without selecting one renders initiation defective; similarly, failing to specify the relevant 271AAB(1A) clause is invalid because the clauses impose distinct conditions and penalty rates. Alleged cheque-paid salary returned in cash supports only a limited bogus-salary disallowance. The penalties fail for want of definite notice, while the expense disallowance remains limited.

Unexplained-money additions based on seized loose sheets require evidence establishing the assessee's ownership of, or nexus with, the recorded cash entries. Entries lacking the assessee's handwriting, signature, identifiable contributors, independent verification, or other corroboration cannot alone support the addition, particularly where the preparer's statements are contradictory and undisclosed. Election-related receipts and payments recorded in May 2019 fall in financial year 2019-20 and, if taxable, relate to Assessment Year 2020-21 rather than Assessment Year 2019-20. The addition was therefore deleted for the year under consideration.

Reassessment jurisdiction under Sections 147(1) and 148 requires the Assessing Officer to form a bona fide belief, based on relevant tangible material, that income chargeable to tax has escaped assessment. Recorded reasons stating only that claims required verification or that supporting particulars were unavailable establish, at most, a reason to suspect. Where available financial statements were not scrutinised and no belief of income escapement was recorded, the statutory jurisdictional conditions were not met; the Section 148 notice and consequential reassessment were without jurisdiction and quashed.

Section 69 applies to investments not recorded in the taxpayer's books and does not permit aggregate bank credits to be treated automatically as unexplained investments without identifying an unrecorded asset or investment. Where date-wise cash transactions are furnished, withdrawals are followed by deposits, and debit entries substantially correspond with credits, the bank-account pattern may show circulation of funds rather than undisclosed investment. On those facts, the addition based on aggregate cash deposits and other bank credits was deleted, with only a nominal closing balance remaining unexplained.

Profits from disclosed BSE futures and options transactions cannot be treated as unexplained cash credits where financial statements record them as operational revenue and contract notes, tax records, bank statements, annual accounts, transaction statements and confirmations establish their genuineness. The absence of evidence that brokers or counterparties were tainted, or that profit-making trades were pre-arranged, distinguishes such transactions from artificial loss arrangements involving reversal trades. On the preponderance of probabilities, the transactions were genuine; therefore, the cash-credit addition and the consequential alleged commission-expenditure addition were deleted.

Taxability of salary from foreign employment depends on the individual's non-resident status and whether the income accrued in India. Employment records showing work for a foreign entity abroad, together with passport entries and NRE account records evidencing USD receipt, are relevant to those questions. The absence of foreign tax returns, a tax residency certificate, or proof of foreign tax payment alone does not establish that the salary accrued in India or justify Indian taxation.

Reassessment under Section 147 remained valid because investigation material from a search established a nexus between accommodation-entry operators and the loan creditors. However, additions for alleged bogus loans were deleted where confirmations, income-tax returns and banking records of the creditors were produced, the loans were fully repaid in the following financial year, and no corresponding addition was made for that year. Repayment through banking channels negated the allegation that the loans were accommodation entries; consequently, the related estimated unexplained expenditure addition had no basis.

Bona fide pursuit of settlement under the Vivad Se Vishwas Scheme, followed by rejection of the settlement form, non-resident status, and ensuing circumstances constituted sufficient cause to condone the filing delay. Cash deposits in a jointly held NRO account were not taxable as the assessee's unexplained investment where passport and bank records supported accumulated foreign earnings, remittances, and withdrawals from that account, and four family members held the account jointly. The cash-deposit addition was therefore deleted.

Section 69A requires a satisfactory explanation of the nature and source of jewellery found in a taxpayer's possession. Valuation reports for the taxpayer and family members may support a claim that jewellery is old and derived from ancestral inheritance and gifts accumulated over time. CBDT Instruction No. 1916 operates as a guiding measure in assessing explained family jewellery, with family status, customary practices and relevant circumstances considered. Jewellery within the family-based benchmark, including marginal excess, was treated as reasonably explained rather than taxable unexplained income.

Section 50C does not apply where consideration is received for relinquishing an unregistered contractual right to seek specific performance of a land-sale agreement. Such a right is a capital asset, and its relinquishment constitutes a transfer, but it does not amount to transfer of land, building, or both. The deeming fiction in Section 50C must be construed strictly and cannot extend to a contractual right concerning land. This differs from a registered leasehold interest, which creates an interest in rem with possession and enjoyment. Long-term capital gains cannot be recomputed under Section 50C on this basis, and the consequential addition is deleted.

Approval for reassessment under section 151 requires proper and independent application of mind to the alleged escaped income. Where sanction was obtained on a materially higher alleged amount than the amount subsequently adopted in the order under section 148A(d), the discrepancy indicates uncertainty in the basis for reopening. Such a material variation renders the sanction legally unsustainable, invalidates the approval, and prevents reassessment initiation from being sustained.

Reassessment initiated on information about interest income cannot be sustained where no addition is made on that recorded ground and the resulting addition concerns alleged unexplained bank credits. An addition on a different issue, without any addition for the reason recorded to reopen the assessment, renders the reassessment and consequential addition unsustainable.

Search-triggered information suggesting escaped income requires use of the special assessment mechanism under section 148 rather than continuation of a regular assessment under section 143(3). The special search-related procedure prevails over the general assessment framework because it preserves statutory safeguards applicable after a search under section 132. Accordingly, a regular assessment completed under section 143(3) after the search was treated as legally unsustainable and quashed.

Section 69A applies where money or valuable articles owned by an assessee are not recorded in its books. A recorded subscription to secured redeemable non-convertible debentures, reflected as a liability and supported by subscriber identification, banking records, audited financial statements, corporate approvals, listing permissions and trust documents, could not be treated as unexplained money without evidence that it represented the assessee's undisclosed funds. Investigation material concerning alleged accommodation entries lacked a direct nexus with the relevant assessment year. The human-probabilities test could not replace material evidence disproving the documented transaction, rendering the addition unsustainable.

Section 68 applies only to sums credited in books maintained by the taxpayer; a bank passbook or account statement is not such books where no books are kept. Accordingly, the cash-deposit addition was removed. Claims for indexed conversion charges and other improvement costs require verification of evidence, timing, nature and nexus to the transferred land before capital-gains deduction. Claims concerning capital gains on property allegedly owned by a former spouse and foreign rental income must be examined when raised in DRP proceedings, even if absent from draft-order variations. A fresh Section 54F exemption claim lacking verified facts on investment, ownership and statutory conditions cannot be entertained at the Tribunal stage.