Reassessment jurisdiction under sections 147 and 148 requires recorded information that is specific to the assessee and the relevant assessment year. Explanation 2(i) does not permit reopening solely on generic group-search allegations without identified seized material, escaped income, or year-specific nexus. Approval under section 151 must reflect application of mind to those particulars. Further, other income may be assessed only after assessing or reassessing the income forming the recorded basis for reopening. A reassessment cannot therefore rest solely on a disallowance of delayed employees' welfare contributions unrelated to the recorded search-based allegations.

First appellate orders under Section 250(6) must identify the points for determination and record decisions supported by reasons. Reliance primarily on the absence of further submissions and the assessment conclusion, without independently considering the agreement date, registration date, payment evidence, and applicability of the addition, does not meet that requirement. The deficiency requires fresh determination in accordance with law.

The tolerance-band proviso to section 56(2)(x)(b) applies retrospectively to Assessment Year 2018-19 because it is curative and clarificatory, addressing hardship caused by marginal differences between purchase consideration and stamp-duty value. Comparable tolerance provisions in sections 50C(1) and 43CA(1), together with the legislative intent underlying the prescribed margin, support that application. Where the stamp-duty-value variation falls within the 5% tolerance band, no income is deemed to arise under section 56(2)(x)(b), and no addition is warranted.

Unexplained expenditure on alleged purchases is taxable in full where the taxpayer cannot substantiate the purchases or their source. Section 69C applies when no satisfactory explanation is provided and prevents deduction of the unexplained expenditure. Where suppliers are accommodation-entry concerns and there is no evidence of actual delivery, transport, stock, receipt, or consumption of goods, an estimated addition based on presumed grey-market purchases lacks evidentiary support. The entire bogus-purchase amount is therefore liable to addition; limiting the addition to an estimated profit element is not permissible.

Jurisdictional challenge to a reassessment notice was admitted under Rule 27 because it raised a pure legal ground going to the root of the reassessment. Determining whether the officer issuing the notice possessed jurisdiction on the issuance date requires examination of the applicable assignment, transfer, and jurisdictional records. As those records were unavailable, the notice's validity could not be conclusively determined and remains subject to verification of the relevant jurisdictional material.

Reassessment under Sections 143(3) and 147 cannot be initiated where its foundation is material seized in a search of a third party concerning another assessee. In that situation, the search-assessment framework under Sections 153A and 153C governs assessment of the other person. Binding jurisdictional High Court precedent prevails over a contrary non-jurisdictional view. Accordingly, reassessment initiated outside the prescribed search-assessment mechanism is without jurisdiction and invalid, requiring quashing of the reassessment order.

Enhanced penalty for under-reporting arising from misreporting applies only when the Revenue identifies and proves a specific statutory circumstance of misreporting. Exclusion from penalty immunity likewise depends on establishing an enumerated misreporting circumstance; a general allegation is insufficient. An alleged political-party accommodation-entry modus operandi cannot, without assessee-specific material, establish participation in such an arrangement. Cheque payment, the party's registration when payment was made, withdrawal of the claim after notice, tax payment, and acceptance of revised income may be relevant where no specific factual nexus is established.

Section 80GGC requires an eligible political contribution to be genuine. Banking-channel payment, a donation receipt and political-party registration are relevant but do not conclusively establish genuineness. Under the test of human probabilities, evidence of an accommodation-entry arrangement, inconsistencies in computations, incomplete bank records and an unexplained contribution may defeat the deduction. A disallowance based cumulatively on third-party material and deficiencies in the taxpayer's own evidence need not breach natural justice merely because cross-examination was unavailable; the procedural objection must affect the determination.

For an unexplained share-capital addition, the assessee must establish the investor's identity and creditworthiness and the transaction's genuineness. PAN details, banking-channel payments, bank records and foreign inward-remittance documents may establish both the immediate source and the investor's source of funds. In the absence of evidence that the investor lacked financial capacity, was a paper entity, or routed the assessee's own unaccounted money through an accommodation entry, the receipt is explained. Non-compliance with foreign-exchange reporting, valuation or downstream-investment requirements falls within the relevant regulatory regime and, by itself, does not make otherwise explained share capital taxable as unexplained income.

Interest income earned by a credit co-operative society from investments with co-operative banks qualifies for deduction under Section 80P(2)(d). That provision covers interest or dividend income derived from investments with another co-operative society. Section 80P(4) bars co-operative banks from claiming deduction under Section 80P in their own right, but does not remove their status as co-operative societies when assessing a depositor co-operative society's deduction under Section 80P(2)(d). Consistent co-ordinate decisions support eligibility of such investment interest for the deduction.

Reassessment remained valid because the challenge lacked support from the recorded reopening reasons or the approval for reopening. Cash deposits could not be accepted as business receipts without supporting evidence for the claimed cosmetics and confectionery sales. However, the deposits were followed by cash withdrawals and cheque payments whose destinations were not examined. Given the depositor's status, absence of books, scale of deposits and passage of time, income from the deposits was confined to a lump-sum amount inclusive of returned income, and the remaining addition was deleted.

Section 68 requires an assessee to establish the genuineness of penny-stock share transactions and the source of sale receipts. Banking-channel payments, contract notes and demat records may not establish genuineness where abnormal price movements, thin or manipulated trading, regulatory findings, identified exit providers, and failure to answer summons point to a pre-arranged accommodation-entry arrangement. Such circumstances can support treating sale proceeds as unexplained credits and estimating related commission expenditure under Section 69C. Natural justice requires disclosure of adverse material, but cross-examination is not indispensable when third-party statements are not the sole or principal basis and corroborative material has been confronted.

Interest on excess refund under Section 234D applies only when the refund becomes recoverable on a regular assessment. A regular assessment ordinarily means an assessment under Section 143(3) or Section 144; Explanation 1 extends this to an assessment made for the first time under Section 147 or Section 153A. Where an assessment under Section 143(3) has already been completed, a later reassessment under Section 147 is not a first assessment and therefore is not a regular assessment for Section 234D. Interest under Section 234D is consequently not chargeable on excess refund determined in that reassessment.

Reassessment initiated more than three years after the relevant assessment year required a recorded determination that income chargeable to tax had escaped assessment at or above the prescribed threshold under Section 149(1)(b). Aggregate cash deposits in a bank account alone did not establish escaped income. Because the order under Section 148A(d) contained no categorical quantification satisfying that condition, the statutory precondition for extended reopening was absent. The notice under Section 148 and consequential reassessment were void ab initio and quashed.

Penalty for concealment or furnishing inaccurate particulars was unsustainable where fixed deposits accepted under a public deposit scheme were supported by depositor names, addresses and transaction details. Although the credits were added as unexplained because confirmations were unavailable and the required standard of proof was not met, no external material or enquiry showed that the deposits constituted undisclosed income. The explanation that certain deposits were renewals from an earlier year, supported by available particulars, was not wholly untenable or lacking in bona fides. An addition under a deeming provision alone did not justify penalty, which was deleted.

Long-term capital gains from documented share sales cannot be treated as bogus accommodation entries solely on an investigation report or general allegations of price rigging. Contract notes, bank records, and demat statements substantiating broker-mediated purchase and sale transactions require contrary evidence linking the taxpayer to entry providers, synchronised trading, cash exchanges, or the alleged manipulation. In the absence of an assessee-specific money trail, incriminating statement, or other connecting material, presumptions cannot displace documented transactions; the addition as unexplained credit was deleted.

Reassessment is not based on a change of opinion where the original assessment did not specifically examine eligibility for agricultural-land reinvestment relief or determine total commission income, and there is reason to believe income escaped assessment. Deduction under section 54B may remain available where a binding agreement to sell created enforceable rights, consideration was received, and that consideration funded replacement agricultural land acquired before registered conveyance. Differential commission income cannot be added when tax-credit records and financial accounts establish the actual commission receipts, including evaporation loss, and the higher figure lacks evidentiary support.

Limited Scrutiny confines assessment to the notified CASS issue. A deduction for donations for scientific research is legally distinct from an eligible company's expenditure on an approved in-house research and development facility, although both arise under section 35. Examination of the latter claim required credible tax-evasion information, recorded reasons and prior administrative approval. A section 142(1) questionnaire, taxpayer participation, Form 3CL, or curative provisions could not expand jurisdiction. The resulting disallowance was invalid.

Unexplained-investment additions require credible material establishing that the assessee actually made the alleged payment. An unsigned agreement to sell, particularly where its stated execution predates purchase of the stamp paper, lacked evidentiary reliability. The seller's affidavit and disputed agreement were insufficient without independent corroboration of funds flowing from the assessee, especially where the property was conveyed to another person and the assessee denied the transaction. The unexplained-investment addition was therefore deleted.

Failure to examine the difference between purchase consideration and stamp-duty value of immovable property may trigger Section 56(2)(vii)(b). Under Explanation 2(a) to Section 263(1), an assessment made without inquiries or verification that should have been undertaken is erroneous and prejudicial to Revenue interests. Where no material shows that the Assessing Officer consciously examined the issue or adopted a sustainable view, limited revision directing fresh inquiry on that issue does not amount to substituting the Assessing Officer's opinion.