Rectification under section 254(2) is limited to an obvious, patent mistake apparent from the record, identifiable without prolonged reasoning or a fresh factual examination. Reconsideration of limitation findings based on dispatch and postal records, service at an incorrect address, notice-server material, approval records, later-cited authorities, or fresh contentions requires reappreciation of disputed evidence. Such reconsideration is an impermissible review, not rectification. A debatable issue or an alternative view cannot support amendment of an earlier Tribunal order under section 254(2).

Cash payments exceeding the applicable daily threshold may not warrant disallowance where they are genuine business payments and are satisfactorily explained. Section 40A(3) targets the circulation of unaccounted money rather than legitimate commercial transactions. In an unorganised, cash-based liquor trade, the factual business environment supported the explanation for cash payments to the supplier. The payments were treated as genuine and explained, resulting in deletion of the disallowance.

Penalty for concealment of income initiated during reassessment proceedings loses its foundation where those reassessment proceedings have already been quashed. The validity of penalty under Section 271(1)(c) depends on the continuing existence of the reassessment in which it was initiated. Once that underlying reassessment is set aside, the consequential concealment penalty cannot survive and is liable to be deleted in favour of the assessee.

Business-loss set-off and consequent tax computation in return processing require verification where adjusted income does not reconcile with tax determined. Entry and adoption of deemed income under section 115JC is not, by itself, erroneous, but its interaction with loss set-off, applicable judicial precedents, and later-year records must be reconsidered. Fresh determination after hearing is required to correct computational discrepancies and prevent double deduction of carried-forward losses.

Limitation restricts orders treating a taxpayer as in default for failure to collect tax at source under Section 206C(6A), even where no express statutory period applied at the relevant time. The power must be exercised within a reasonable four-year period from the end of the relevant financial year; delayed proceedings are time-barred, and consequential interest under Section 206C(7) does not survive. A limitation objection may be admitted as an additional ground where it is a pure legal issue, all material facts are already on record, and no further factual inquiry is required. The subsequently inserted Section 206C(7A) does not govern earlier orders.

Related-party interest paid at a rate accepted as arm's length in an identical transaction for the immediately succeeding assessment year requires consistent treatment under Section 40A(2) of the Income-tax Act. Applying the prior coordinate-bench position, the interest disallowance was deleted. Acceptance of the rate in materially identical circumstances supported allowance of the related-party interest expenditure.

Final settlement under the Vivad Se Vishwas Scheme conclusively closes the assessment dispute concerning the relevant tax arrears. Once the competent authority issues a full and final settlement order, the underlying assessment cannot be reopened through revisionary jurisdiction under Section 263. Revisionary proceedings initiated after such settlement are therefore impermissible, and the original assessment remains restored.

Bank-account credits arising from agricultural-loan disbursements and recoveries cannot, without further factual material, support a presumptive-profit addition at 8%. Correspondence between substantial withdrawals and deposits, together with the entity's registered cooperative lending activities, supports the explanation that the entries represent loan flows rather than business receipts. In the absence of evidence of another business activity or a factual basis for the profit estimate, the addition was unsustainable and deleted.

Post-search assessments for preceding assessment years covered by Explanation 2 to section 148 must follow the special reassessment mechanism under sections 147 and 148. The deeming fiction of escapement of income displaces direct scrutiny assessment under section 143(3); neither administrative selection nor taxpayer participation can cure the absence of a jurisdictional reassessment notice. Prior approval under section 148B is mandatory before assessment, reassessment, or recomputation and requires independent consideration of relevant seized material. General supervisory or administrative approval cannot substitute for this statutory safeguard. Non-compliance with either requirement renders the assessment void for lack of jurisdiction.

Section 14A read with Rule 8D does not permit disallowance of expenditure relating to exempt income where no exempt income was earned or received in the relevant year. For Assessment Year 2017-18, this rule precludes the proposed disallowance. The Finance Act 2022 amendment applies prospectively from Assessment Year 2022-23 and does not affect the earlier year.

Section 68 treatment of unlisted-share sale proceeds requires consideration of supporting transaction records, including PMS registration, portfolio and capital-gains statements, valuation documentation and demat delivery instructions. Non-disclosure in a return schedule, without contrary material or a valuation defect, does not by itself displace evidence of purchase and sale. Corporate filings and shareholder records may substantiate original subscription cost and indexed acquisition cost despite unavailable historic bank slips. A partner's share of LLP profit, accepted as such, is exempt and cannot be treated as unexplained cash credit.

Section 69A applies only where the source of money is not satisfactorily explained. Contemporaneous cash withdrawals, returned income, rental income and property-sale proceeds may together establish the availability and source of funds for a cash deposit, preventing its treatment as unexplained money. Delay in filing an appeal may be condoned on sufficient cause where an appellate order went unnoticed during a tax professional's illness and the taxpayer acted promptly after learning of the outstanding demand.

Political-contribution deductions require a genuine contribution. Banking-channel payments and donation receipts do not by themselves establish genuineness where investigation material, physical verification, recipient party non-compliance, and fund layering indicate an accommodation-entry arrangement. Applying human probabilities and preponderance of probabilities, the claimed donation did not represent a genuine political contribution. The deduction claimed under Section 80GGC was therefore disallowed.

Revision under Section 263 requires an assessment order to be both erroneous and prejudicial to the Revenue's interests. Construction expenditure treated as unexplained investment had been examined by the Assessing Officer and brought to tax in subsequent assessment years. Since the expenditure was already assessed in those years, no further addition was warranted in the earlier assessment year. The conditions for invoking revisionary jurisdiction were therefore not satisfied, and the revision order was quashed.

Unexplained-expenditure additions under the Income-tax Act require a sustainable evidentiary basis and cannot rest solely on an uncorroborated third-party statement when cross-examination is denied and statutory enquiry supports the taxpayer's explanation. Rule 46A governs the admission and verification of additional evidence, including opportunities for the Assessing Officer to examine the material. A payer's failure to deduct tax at source does not by itself alter the character of the recipient's receipts, because the deduction obligation rests with the payer. Books of account, payment records, job-work registers, delivery records and payer confirmations may corroborate disclosed job-work receipts.

Penalty under Section 271(1)(c) for concealment or furnishing inaccurate particulars is not attracted merely because an addition is made on a debatable issue. An addition relating to an area development fund involved a matter considered by the Supreme Court in comparable proceedings, supporting its debatable nature. Where relevant particulars were disclosed during assessment, the addition alone does not establish concealment or inaccurate particulars. Penalty on that addition is therefore not imposable and must be deleted.

Search-derived material following a Section 132 search triggers the special reassessment framework under Sections 147 and 148, including the deemed-information rule in Explanation 2 to Section 148. Where an assessment relies on that material and related statements, a pending Section 143(3) scrutiny cannot continue merely because a Section 143(2) notice was previously issued; the special mechanism prevails over the general scrutiny route. Section 148B separately requires prior statutory approval. Approval under an administrative CBDT instruction, even by the relevant approving authority, does not meet that mandatory requirement. Non-compliance renders the assessment unsustainable, leaving the Section 69C addition unexamined on merits.

Revisionary jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer specifically examines employee stock option scheme expenditure, considers supporting material and accepts the claim, a brief assessment order does not establish inadequate inquiry. Employee stock option discount may constitute employee compensation and deductible revenue expenditure under section 37(1). A pending challenge to precedent, without stay or reversal, does not alter that position. Revision cannot substitute the Principal Commissioner's view for a permissible view reached after inquiry.

Section 68 is inapplicable where purchases are capitalised as construction work-in-progress, no corresponding credit appears in the books, and purchase records are supported by tax filings, supplier evidence, invoices and audited accounts. Share application money is explained when the applicant's identity, creditworthiness and transaction genuineness are established through corporate, financial and banking records, absent material linking the assessee to alleged entry operators. Declared agricultural income is not unexplained credit where land ownership, production, sales and expenditure evidence substantiate cultivation and higher realisation is supported by the nature of the produce. The three additions were deleted.

Assessment of a company struck off and dissolved requires restoration of its legal existence through the prescribed corporate-law process before proceedings may be initiated or continued. Participation in proceedings does not cure the jurisdictional defect of assessing a non-existent entity. An outward bank remittance made through banking channels for import purchases is an application of funds, not unexplained money. Such an addition requires proof that the assessee owned unrecorded money or another specified valuable article; an unproved source of expenditure cannot replace that ownership requirement.