Restoration of the statutory customs appeal was warranted because prior withdrawal, dismissal of the writ petition, and refusal to recall the appeal had deprived the appellants of any appellate consideration on merits. The right of appeal operates as a valuable remedy requiring at least one appellate forum to address an aggrieved party's grievance. The appellants may pursue their appeal before CESTAT, which must decide it on merits within the stipulated period.

Unchallenged settlement deed confers absolute title on the testatrix where no relief is sought to set it aside, preventing a partition claim founded on an alleged benami purchase. A testamentary disposition made by the absolute owner governs succession to that property. Due execution and attestation of a registered Will require compliance with the statutory requirements for execution and proof through attesting-witness evidence. Alleged suspicious circumstances, including age, health, place of registration, or the executor's role, do not invalidate the Will unless supported by acceptable evidence. Registration at the testatrix's residence alone does not create suspicion.

Rule 27 permits a respondent to support the appealed order on a ground decided against it, but does not enlarge the appeal or allow a fresh jurisdictional challenge seeking annulment of reassessment where that challenge was not raised before the first appellate authority. Cash deposits are not unexplained money where bank statements, audit reports and financial statements already on record show disclosed business turnover exceeding the deposits, with related payments supporting their business-receipt character. Absence of an Assessing Officer's remand report on examination of books does not justify an addition when the deposits are otherwise satisfactorily explained.

Salary expenditure disallowed under Section 40A(3) required fresh verification because ledger extracts, cash book entries and other supporting material needed examination by the Assessing Officer. Adequate opportunity was required to substantiate the genuineness of the expenditure. The matter was restored to the Assessing Officer for fresh examination of the supporting material and the salary-expenditure disallowance.

Penalty under section 271AAB applies only where surrendered income meets the statutory definition of undisclosed income. A search disclosure alone does not establish that status. Where technical-services expenditure is recorded in regular books and supported by bank payments, bills and tax deduction, its mere non-verifiability does not establish a false entry. Classification as undisclosed income requires material showing falsity that emerged during the search, such as incriminating evidence, forged documents, a non-existent supplier or lack of actual services. On those facts, the surrendered amount falls outside the undisclosed-income definition and no penalty is sustainable.

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.