Section 41(1) applies only where a prior allowance or deduction exists and the taxpayer obtains a benefit through actual remission or cessation of a trading liability during the relevant year. Outstanding trade-creditor balances that remain acknowledged in the accounts do not become taxable solely because they are old, unconfirmed, unrecovered, or time-barred; waiver, settlement, write-back, discharge, or another event evidencing cessation or benefit is required. Interest for deferment of advance tax under section 234C is mandatory but, for a company, must be computed on tax due on returned income after statutory adjustments and credits, rather than on assessed income merely because the assessment income is higher.

Article 12(4)(b) of the India-Singapore tax treaty treats technical, managerial or consultancy services as fees for technical services only where they make available technical knowledge, experience, skill, know-how or processes for independent use by the recipient. Recurring software maintenance, remote support, bug resolution, standard updates and user training do not meet that condition where customers remain dependent on the service provider. Software migration from an old version to a new version likewise does not qualify without transfer of independent technical capability. Such receipts are business receipts and are not taxable in India absent a permanent establishment.

Section 115UB(2A) deems eligible non-business losses accumulated by an investment fund as on 31 March 2019 to be losses of unit holders holding units on that date. A unit holder may carry forward the attributable loss for the remaining statutory period and set it off under Chapter VI. Attribution must be made on a pro-rata basis through the fund's statement, with verification that the loss was attributed to the unit holder and was not available to the fund after 1 April 2019.

Identified unrecorded sales constitute business turnover, not unexplained money taxable in full; taxability is confined to a 5% profit estimate after removing duplicated sales. Cash salaries and supplier payments connected with the same unrecorded trading activity are subsumed in that estimate and cannot be separately added without a distinct source or expenditure, avoiding double addition. Alleged cash investment requires reliable evidence identifying the payer, payment and relevant year; common workbook entries and statutory presumptions alone are insufficient. Accounted cash and explained trading realisations are not unexplained money. For stock, only the physical-to-book valuation difference is considered, with overlap eliminated.

Under the mercantile system, an accrued liability for investors' share of profit is deductible where its existence and accrual under the relevant arrangement are undisputed. Section 43B's payment-basis restriction applies only to specified liabilities and does not extend to this profit-sharing obligation. Outstanding non-payment or lack of funds does not render the liability contingent unless evidence shows that it never accrued or has ceased. Subsequent payment supports the liability's continuing existence; the related disallowance is therefore not sustainable.

Statutory assessment limitation may be extended on the basis of a foreign-tax reference only where evidence of the reference substantiates the extension; an unsupported assertion leaves assessments time-barred and void from inception. In search assessments for unabated years, expenditure recorded in regular books cannot be disallowed without seized incriminating material. Agreements, invoices, banking records and confirmations can establish the genuineness of excavation expenses and professional charges included in work-in-progress and discharge the taxpayer's burden of proof. On those principles, the expense additions were unsustainable and the assessment orders could not stand.

Recorded cash balance may explain bank deposits made during demonetisation where the cash in hand immediately before demonetisation exceeds the deposits and the cash book, bank entries and stock records contain no identified discrepancy. Section 68 permits scrutiny of the nature and source of credits, and the human-probabilities test allows examination beyond book entries, but neither justifies disregarding recorded cash solely through an estimated cash-sales ratio. Where no fictitious sale, unexplained deposit or defect in cash-flow records is identified, and the ratio is not an independent historical benchmark, the recorded balance adequately explains the deposits. The addition for alleged inflated cash sales was deleted.

Failure to attend the hearing, seek an adjournment, or provide written submissions and supporting material may justify dismissal of an appeal for non-prosecution where adequate and reasonable opportunity has been given. Appellate tribunals possess inherent power to dismiss proceedings when an appellant neither appears nor pursues the matter, as continuing such proceedings serves no purpose. The appeal was dismissed for non-prosecution, while preserving liberty to seek recall by substantiating reasons for non-compliance with the hearing notice.

Section 148 reassessment limitation permits only the time surviving from an earlier reassessment notice deemed to be a show-cause notice under Section 148A(b), after excluding time for supplying material and receiving a reply. Where the surviving period is below seven days, the statutory minimum period of seven days applies. A fresh notice issued after that period, even on calculations most favourable to the Revenue, is time-barred. A later communication merely re-supplying material already furnished does not revive or restart limitation. Reassessment founded on such a notice is without jurisdiction.

Section 50C applies to transfers of tenancy rights in land or a building because the mode of holding the property does not alter its character for stamp-duty valuation purposes. Distinctions between leasehold and tenancy rights may affect the nature or value of the transferred interest, but do not exclude the transfer from the provision. Where an assessee claims that the stamp valuation exceeds fair market value and seeks a valuation reference, the statutory conditions under section 50C(2) must be examined. If satisfied, valuation by the Departmental Valuation Officer is required before determining full value of consideration.

Non-genuine purchases supported by accommodation bills cannot be added in full where the corresponding sales are accepted. Procurement through the grey market may justify an addition limited to the profit element embedded in those purchases, rather than their entire value. A 25% profit estimate lacked material support where the assessment record indicated that the relevant grey-market margin would not exceed 8%. The addition for the disputed purchases is therefore restricted to 5% of their value.

Section 14A disallowance requires factual verification where sponsorship-related expenditure is claimed and exempt-income investments exist. The expenditure must be examined to determine whether it relates exclusively to sponsorship income rather than investments producing exempt income; any adjustment is to be restricted under Rule 8D(ii). Income offered on a gross basis does not remove the need for that verification where specific expenditure has been claimed. Earlier assessments containing no disallowance do not bar examination in a later year, because each assessment year is separate and res judicata does not apply to income-tax assessments.

Where declared sale consideration for immovable property is disputed against the stamp-duty valuation, the Assessing Officer must obtain a Departmental Valuation Officer's determination of fair market value before using the stamp-duty value for capital-gains computation under Section 50C. Without that valuation reference, the stamp-duty valuation cannot replace the declared consideration in the stated circumstances.

Rectification under section 154 is confined to a mistake apparent from the record and cannot reopen a sales figure already examined and accepted during the original assessment. Where sales were verified against VAT returns and a higher return figure was treated as a typographical error, an audit objection identifying the discrepancy alone did not establish an apparent mistake or displace the prior verification. Reliance solely on that objection amounted to borrowed satisfaction rather than an independently identifiable record-based error. The rectification was invalid, and the resulting sales addition was deleted.

High-turnover, branded companies with materially different scale, brand value, operational capacity, and functions-assets-risks profile are not comparable to a captive software development service provider and should be excluded in determining the arm's-length price. Interest on delayed associated-enterprise receivables must be benchmarked by reference to the invoice currency. Where invoices are USD-denominated, LIBOR plus an appropriate mark-up, or another suitable currency-appropriate rate, applies rather than the SBI rate. The transfer-pricing computation consequently requires revised comparables and a currency-aligned interest benchmark.

Misreporting penalties require a precise charge in the penalty notice; a notice alleging only under-reporting cannot support a penalty imposed for under-reporting arising from misreporting. A deduction claim that is fully disclosed, bona fide and debatable, particularly amid conflicting judicial views, falls outside misreporting unless it is shown to meet a specified statutory category. Where the taxpayer discloses all material facts and gives a bona fide explanation, the under-reported-income exclusion applies, so a penalty founded on disallowance of that claim lacks statutory basis.

Penalty for under-reporting of income consequent on misreporting under section 270A was unsustainable where the claimed cost of improvement was disclosed in the return and supporting particulars. Disallowance based only on inadequate documentary evidence, particularly for incidental local purchases and labour payments, did not establish suppression or misrepresentation when the improvement work itself was undisputed. Contractor-level documentation was not required in those circumstances, and the penalty was quashed.

Cash deposits in a proprietary concern's bank account may be explained through reconstructed cash books, monthly sales summaries and daily sales registers where they align with declared turnover and regular deposit patterns. Customer-specific particulars for retail cash collections are not warranted in those circumstances, particularly where turnover is taxed under the presumptive-taxation scheme. The disputed deposit was consistent with normal retail sales and could not be sustained as unexplained cash credit.

Appellate authorities may entertain legitimate deductions under Sections 80C and 80CCD(1B) that were omitted from an original return and not claimed through a revised return. A taxpayer's lack of awareness should not, by itself, defeat an otherwise eligible statutory deduction. Supporting evidence of investments in notified PPF and National Pension Scheme arrangements may be admitted under Rule 29 where it is material to determining entitlement, subject to verification. Following verification of the admitted evidence, the claimed deductions are to be allowed.

Failure to substantiate the source of stamp-duty and registration payments supported an addition for unexplained investment, as the alleged loan lacked confirmation, proof of transfer, and other corroboration. A stamp-duty valuation exceeding the declared property consideration was treated as deemed income because the claimed effect of longstanding tenancy was unsupported by independent valuation evidence or proof of a lower fair market value, and no statutory valuation reference was sought. Unrebutted search material showing cash paid for the property supported a further addition as unexplained money, with no seller confirmation or reliable contrary evidence produced.