Documents already relied upon in a show cause notice do not constitute new evidence when placed before the appellate forum. An additional ground may identify the corroborative effect of existing record material without introducing a new case. Further judicial authorities may be cited, and reliance on previously cited authorities may be withdrawn. The departmental appellant was permitted to file the existing documents and amend the appeal, subject to supplying copies to the respondent.

Cash received and subsequently routed through a bank by an assessee acting solely as a mediator in a property transaction between relatives was treated as neither a loan nor a deposit for the cash-acceptance restriction. The intermediary role, supported by documents and evidence, established reasonable cause and attracted statutory protection from penalty. Consequently, the penalty for accepting cash as a loan or deposit was deleted.

Reassessment founded on an audit objection requires the Assessing Officer to verify the record and independently apply mind. An allegation that health and education cess had been deducted could not support reassessment where no such deduction was claimed and the audit premise was unverified. Interest on borrowed funds invested in a subsidiary must be assessed through commercial expediency from a prudent businessperson's standpoint; reassessment could not proceed where that governing principle was not distinguished on recorded facts. The reassessment notices and order were quashed.

Revision of an income-tax intimation requires consideration of expenditure disclosed in the return when computing income; overlooking that material indicates non-application of mind. The revision order was quashed because it proceeded on an incomplete computation. Rejection of a rectification application must be reasoned and address the taxpayer's claim. As the rejection communication and original intimation neither considered disclosed expenditure nor gave reasons, both were quashed. Fresh rectification was directed to be reconsidered after examining the return.

Revisional jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Revision cannot rest merely on Insight Portal information that the Assessing Officer already examined during reassessment, where the officer considered explanations and supporting evidence showing that the alleged accommodation-entry transactions did not concern the assessee. The revisional authority must identify discrepancies in the material examined or conduct further inquiry; it cannot substitute its view merely because additional inquiry was possible. Sufficient inquiry by the Assessing Officer distinguishes an impermissible review for allegedly inadequate inquiry from a valid revision based on lack of inquiry.

Section 170A(2)(a) limits a modified return filed after business reorganisation, where assessment or reassessment had already concluded, to adjusting total income to implement the reorganisation. It does not permit the modified return to be treated as a return under section 139 or to initiate fresh scrutiny under section 143(2); information may be sought only to verify implementation. Transfer-pricing jurisdiction initiated on the premise of valid pending scrutiny does not survive if that scrutiny notice lacks authority. A writ challenging the assumption of statutory jurisdiction remains maintainable despite assessment participation or an appellate remedy. The scrutiny and consequential transfer-pricing proceedings were quashed.

Third-party loose sheets may trigger investigation but cannot, without reliable evidence linking the assessee to the recorded transaction, prove unexplained expenditure. Presumptions attached to seized documents apply to the person from whose possession or control they are recovered; they do not establish the alleged payer, source or movement of funds. Actual incurrence is foundational, so an uncorroborated allegation cannot shift the burden of proof. Nor does a third-party reference establish ownership of unrecorded money; the statutory requirements for unexplained money and expenditure are distinct. These deficiencies made both additions unsustainable. Evaluation of material already on the assessment record does not amount to admitting additional evidence.

Revision under section 263 is unavailable where the Assessing Officer has examined a claimed exemption, considered supporting explanations and adopted a plausible view; a different view of the revisional authority does not establish an order that is both erroneous and prejudicial to the Revenue. Interest awarded under section 28 of the Land Acquisition Act for delayed payment of enhanced compensation on compulsorily acquired agricultural land was treated by the majority as an accretion to compensation rather than income from other sources. Accordingly, the revisionary order was quashed and the receipt was not assessed under that head.

Transaction-specific investigation information identifying the taxpayer, supplier and disputed transaction can support reassessment under the substituted regime after pre-notice procedure; its Investigation Wing origin alone does not make it vague. A retrospective clarification permits a Jurisdictional Assessing Officer to issue the reassessment notice. Where corresponding sales, purchase records and banking evidence exist but the named supplier is untraceable and does not comply, purchases cannot be wholly disallowed; absent evidence that payments returned in cash, addition is limited to the embedded profit. The disputed-purchase addition was restricted to 6%. A monetary-limit exception for departmental appeals affects maintainability but does not itself require vacating the appellate order or remanding assessment.

Under TNMM, audited annual accounts and reports provide a reliable basis for comparability analysis over unaudited raw data. Verified working-capital-adjusted margins must reflect differences between tested international transactions and comparable uncontrolled transactions; where the taxpayer's margin falls within that range, no transfer-pricing adjustment is warranted. A claimed duplicate disallowance of interest on income tax requires verification whether a voluntary disallowance was already made in the return; any repeated disallowance must be deleted. Employees' provident fund contributions are deductible only if deposited by the due date under the relevant fund law, requiring verification.

Common expenditure proportionately allocated to taxable non-member receipts of a mutual concern is deductible where the expenses are genuine, relate to earning those receipts, and the allocation method has been consistently followed; an estimated restriction without disclosed basis or cogent material cannot stand. The disallowance was deleted. Rent from terrace space leased to a cellular operator for a tower was treated as income from house property, attracting statutory deductions rather than income from other sources. The appeal succeeded on those issues. The challenge to the scrutiny notice for alleged non-compliance with CBDT instructions was dismissed because a cited Special Bench ruling covered the issue against the assessee.

An appellate authority cannot, after finding the unexplained-expenditure provision inapplicable, delegate determination of the gross-profit rate and consequential addition to the Assessing Officer. Any gross-profit addition must rest on a reasoned determination and cannot be mechanically applied to disputed purchases that include capitalised items without examining genuine comparables, alleged inflation, and differential margins; fresh speaking adjudication is required. Penalty for furnishing inaccurate particulars does not arise merely because a disclosed bad-debt write-off or unpaid-interest claim is disallowed. Where audited accounts, ledgers, liability, and payment details were disclosed, and no falsity, fabrication, suppression, or del.....

Post-1 April 2021 searches are deemed under Explanation 2(i) to section 148 to provide information suggesting that income has escaped assessment. This statutory deeming requires reassessment proceedings under section 148 rather than continuation and completion of a scrutiny assessment under section 143(3). Completing a scrutiny assessment despite the prescribed procedure creates a jurisdictional defect, rendering the assessment invalid. The requirement concerns the mandatory procedural route following a qualifying search.

Section 68 treatment of unsecured loans requires lender non-compliance with notices to be assessed alongside other record material; non-compliance alone does not establish unexplained cash credit. A credit relating to an earlier financial year falls outside the relevant previous year, and bank-channel receipt and repayment supported the other loan; the unsecured-loan addition was deleted. Flat-sale consideration claimed as already taxed requires verification against books and assessment records, so that issue remains for assessment verification. Corpus-fund and society deposits cannot be treated as unexplained or yield notional interest merely because the society was unformed or funds were retained; however, purchaser-wise evidence must be examined before their character and source are determined.

Denial of charitable exemption under section 11 does not by itself justify taxing an educational trust's entire gross receipts. Taxable income must ordinarily reflect real income, determined after verification and allowance of genuine expenditure otherwise admissible in law, unless a provision requires taxation on a gross basis. The computation was restored to the assessing authority to examine the books and determine net taxable income after verifying the claimed expenditure; the appeal was partly allowed for statistical purposes.

Assessment limitation following remand of a transfer-pricing issue is governed by section 153(3) where the remand is to the Assessing Officer under Rule 28 and requires verification and a hearing. A fresh reference to the Transfer Pricing Officer, absent fresh satisfaction under section 92CA(1), does not attract section 153(4) or extend the completion period; the consequential assessment was therefore quashed as time-barred. Although quoting a DIN in Dispute Resolution Panel directions is mandatory, omission from the directions did not invalidate them where a separate authenticated intimation identified the directions and carried the DIN. The DIN objection was rejected.

Compulsory-acquisition compensation for agricultural land in the Hazira Notified Area was not chargeable to capital-gains tax because the land lay outside a municipal area, retained its agricultural character, and was used for agricultural operations. The resulting capital-gains addition on land compensation did not survive. For compensation attributable to built-up structures and other assets acquired with the land, 60 per cent of the relevant compensation was allowable as cost of acquisition when computing consequential capital gains.

Interim judicial restraint preventing treatment of foreign-leg Leave Fare Concession reimbursements as income for tax-deduction purposes meant the deductor did not breach an enforceable deduction obligation; tax-default demands and consequential interest were therefore deleted. Subsequent substantive taxability could not retrospectively turn compliance with the subsisting direction into a default. Compliance with that direction also constituted statutory reasonable cause, supporting deletion of non-deduction penalties. Institutional delays in penalty appeals were condoned where multi-level approvals, lost portal access after personnel changes, and access resetting showed sufficient cause without deliberate delay, mala fides, benefit to the deductor, or prejudice to revenue.

Benami characterisation of land acquired in an apparent purchaser's name rested on cumulative evidence of limited financial means, a statement that the sale deed was signed at the beneficial owner's behest, documented nexus between them, and proof of the payment source. A later retraction affidavit lacked support and was treated as unreliable because it conflicted with the sale deed, was delayed without explanation, and referred to an implausible future event. The land was treated as benami property, sustaining confirmation of provisional attachment.

Interest on IGST levied on imported goods cannot be recovered where neither the Customs Tariff Act, 1975 nor the Customs Act, 1962 contains a charging provision authorising such interest. The issue was treated as settled by earlier precedent, rendering the interest collection unsustainable. Refund claims for interest paid must be considered expeditiously and within 16 weeks of receipt, provided the claimant establishes that the interest burden was not passed on to buyers or customers.