Reassessment after the extended statutory period following a completed scrutiny assessment requires recorded reasons to identify the assessee's failure to make a full and true disclosure of material facts. Reliance solely on an excise duty or VAT adjustment reduced from sales, without identifying any undisclosed material fact, does not satisfy that condition. On the stated facts, the reassessment proceedings were invalid and quashed.

The first proviso to Section 149(1) retains the limitation period under the pre-1 April 2021 reassessment regime for assessment years beginning on or before that date. For Assessment Year 2015-16, where alleged escaped income exceeded the applicable threshold, the former six-year period ended on 31 March 2022. Consequently, a reassessment notice issued on 20 March 2024 fell outside the surviving limitation period, invalidating assumption of jurisdiction under Section 147 and the consequential assessment.

Scrutiny notices under the Income-tax Act need not follow an administrative format where statutory requirements are met and no prejudice arises. Corporate guarantees constitute international transactions requiring arm's length benchmarking; bank-guarantee quotations are not directly comparable to parent-company guarantees, and separate guarantee transactions cannot be netted without proof of close linkage and arm's length character. Certified segmental accounts may require verification before rejecting internal TNMM in favour of external comparables for finished-goods sales. Capital-loss carry-forward depends on timely filing in the year of loss, rather than a later-year belated return, while unabsorbed depreciation carries forward independently, subject to statutory and quantum verification.

Corpus exemption for voluntary contributions depends on a specific, verifiable and contemporaneous direction from each donor that the contribution forms part of the corpus, together with compliance with prescribed investment conditions. A recipient's later classification or directions from an unauthorised group representative cannot replace that donor direction. Reassessment initiated beyond four years requires recorded material showing failure of full and true disclosure and independent prima facie satisfaction rather than a change of opinion. Application of accumulated income to immovable property requires verification of the stated accumulation purpose, funding source, charitable-object nexus and actual use. Statutory accumulation remains available for contributions not accepted as corpus, subject to conditions and no double benefit. A trustee resolution may supplement Form No. 10 where it identifies distinct and sufficiently specific accumulation projects.

Reassessment notice issued under Section 148 more than three years after the relevant assessment year cannot rely on the extended limitation period where the assessee's attributable income escaping assessment is below the prescribed threshold. In a sale by multiple vendors, each vendor's individual share, rather than the aggregate sale consideration, determines the amount attributable to that assessee. Treating the full transaction value as income escaping assessment for one vendor is impermissible where the reassessment accepts a lower individual share. The notice was time-barred, rendering the reassessment order vitiated.

PBDIT should be used as the profit level indicator under the Transactional Net Margin Method where substantially different fixed-asset profiles produce material depreciation differences and no reliable adjustment to comparable operating margins is feasible. Arm's length pricing should then be recomputed using PBDIT for both the tested party and comparables. Working-capital differences affecting operating margins require an adjustment calculated on an actual basis. Eligible brought-forward business losses and unabsorbed depreciation require verification and statutory set-off against assessed income in accordance with law.

Section 292BA cures defects only in an assessment or assessment order and does not extend to an order passed under Section 201(1)/(1A). Proceedings under Section 201(1)/(1A) culminate in an order under that provision, not an assessment order; describing them as assessment-like in another context cannot expand Section 292BA. CBDT Circular No. 19/2019 requires departmental communications to quote a computer-generated Document Identification Number and treats non-compliance as invalidity. Consequently, failure to quote a DIN in a Section 201 order is a jurisdictional defect that Section 292BA cannot cure, rendering the order invalid.

Section 145(3) permits rejection of accounts that are materially incorrect or incomplete; missing ledgers, stock and inventory records, trial balance and balance sheet prevent reliable determination of taxable profit. Following valid rejection, best-judgment net-profit estimation must rest on relevant material rather than unsupported ad hoc rates. The applicable rate requires recomputation using the average declared in the five immediately preceding years, excluding interest income, subject to prescribed benchmarks and special-audit findings. Interest on bank or financial-institution deposits and delayed customer instalments is taxable as income from other sources under Section 56(2), not business income, absent money-lending, financing or banking activity.

Valid Form 15G/15H declarations received from depositors under section 197A(1A), read with section 194A and Rule 29C, remove the payer's obligation to deduct tax at source on interest payments. Section 40(a)(ia) disallowance applies only where tax was deductible but was not deducted, or deducted but not paid. Failure to furnish valid declarations to the prescribed authority attracts the separate penalty framework under section 272A(2)(f); it does not convert the payer into a tax-deduction defaulter or support interest-expenditure disallowance.

Charitable-registration renewal must be assessed against a trust's charitable objects and activities. Private-category medical treatment does not, by itself, establish that a beneficiary lacks financial indigence or economic hardship, particularly where prolonged treatment for a life-threatening illness may exhaust modest resources. Assistance to one beneficiary, even if representing a substantial share of expenditure, does not alone displace the public charitable character of the activities. Renewal could not be refused without any other recorded ground, and the consequential refusal of approval under Section 80G could not survive.

Excess managerial remuneration determined after finalisation and audit of the employer's accounts, and actually recovered in a later previous year, is adjustable in computing that year's salary income. The claim operates as a salary computation adjustment under section 15, rather than as an independent deduction under section 16 or a revision of salary assessed for the earlier year. An enforceable repayment liability must crystallise in the relevant year, with actual recovery supported by audited accounts and banking records. The annuality principle does not prevent recognition of a genuine subsequent recovery.

Completed or unabated assessments under Section 153A may be disturbed only on incriminating material found during the assessee's search that directly relates to the proposed addition. Material obtained through later enquiries, bank analysis, spot verification or third-party searches cannot satisfy that jurisdictional requirement. Unsecured loan credits supported by banking channels, lender confirmations and records, financial documentation, and subsequent banking-channel repayments establish transaction genuineness and lender creditworthiness. Consequently, the loan additions and related interest disallowances do not survive where no qualifying search material exists and the principal loan credits are not sustained.

Rule 128(9), effective from 1 April 2022, permits Form No. 67 for foreign tax credit to be filed on or before the end of the relevant assessment year, rather than by the return-filing due date under section 139(1). For Assessment Year 2022-23, Form No. 67 filed on 31 August 2022 fell within the applicable deadline of 31 March 2023. Foreign tax credit therefore cannot be denied as time-barred and remains allowable, subject to verification of the remaining conditions.

Section 68 applies only to sums credited during the relevant year that remain unexplained. A repayment is not a fresh credit, and an opening balance, repayment transactions and recovery of an advance do not constitute unexplained current-year credits. Banking records evidencing fund movement and the loan support the credit's explanation, rendering the cash-credit additions unsustainable. Discount expenditure in a cotton business is allowable where ledger records establish that it arose from samples, weight shortages and quality issues, was consistently incurred across years, and was proportionate to sales. The discount disallowance was therefore deleted.

Section 56(2)(x) permits stamp duty value to be determined as on the agreement date where registration occurs later. This treatment applies if whole or part of the consideration was paid on or before the agreement date through an account-payee cheque, bank draft, electronic clearing system, or prescribed electronic mode. Payment evidence, bank records, source documents, and applicable circle-rate material support use of the agreement-date value. Non-receipt of information from the Sub-Registrar cannot by itself justify rejecting such evidence or adopting the stamp duty value prevailing on the registration date.

Digital search material, corroborated by registered property-purchase records, can establish an unrecorded cash payment where the taxpayer does not substantiate the claimed cash source. Income-tax computation distinguishes income from gross unrecorded receipts or payments: only the embedded profit element is assessable. Under this approach, the addition is confined to 10% of the proven unrecorded payment and is taxable at normal rates rather than under section 115BBE.

Reassessment notices for Assessment Year 2015-16 issued on or after 1 April 2021 fell outside the period preserved by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, under the Revenue's recorded concession. The notice issued on 25 June 2021 and the consequential notice issued on 27 July 2022 could not be completed within the applicable limitation period. The reassessment proceedings therefore lacked jurisdiction, rendering the reassessment order legally invalid and liable to be quashed.

Loan credits are satisfactorily explained under section 68 when lender identity, prima facie financial capacity and transaction genuineness are supported by confirmation, identifiable bank transfers, financial records and repayment material. General, untested allegations concerning a lender's activities do not rebut transaction-specific evidence without inquiry or material linking the credit to an accommodation entry. Section 69C cannot support an inferred commission addition without proof that expenditure was actually incurred and its source remains unexplained. Interest disallowance cannot rest solely on an unexplained-loan premise that fails, particularly where no separate interest deduction is claimed under the presumptive scheme in section 44ADA.

Articles 6 and 7 of the Multilateral Instrument require incorporation into domestic law through a specific notification under section 90(1) before they can modify India-Ireland DTAA benefits. Without such incorporation, the Principal Purpose Test cannot restrict treaty relief. Valid tax residence, commercial substance and cross-border aircraft leasing do not, by themselves, establish a principal purpose contrary to the treaty's object and purpose. Dry-lease rentals for aircraft used in international traffic fall within Article 8(1) where the lessor operates from Ireland and the aircraft is not at its disposal as a fixed place of business; standard lessor protections do not create a permanent establishment. Retained ownership and repossession rights indicate an operating lease, so rentals are not interest income.

Section 43CA's enhanced 10% tolerance band is treated as a curative measure mitigating hardship from deemed-consideration rules and applies retrospectively to assessment year 2016-17. Transfers with differences within that band do not attract additions based on stamp-duty value. For Flat A-702, the claimed 2011 allotment and banking-channel receipt require verification to determine whether agreement-date stamp value may apply. Where stamp valuation is specifically disputed as exceeding fair market value, statutory verification and, where warranted, reference to the Valuation Officer are required before deemed consideration is determined.