Enhanced penalty for misreporting of income under section 270A requires proof of the specific ingredients in section 270A(9), rather than mere disallowance of a deduction claim. Disclosure of the claim and payment through banking channels may demonstrate disclosure of material facts. General investigation material concerning the recipient's alleged modus operandi does not by itself establish misrepresentation, suppression of facts, or furnishing of false particulars. An inadmissible claim is distinct from misreporting of income, and penalty proceedings require an independent examination; an assessment disallowance is not conclusive. Where statutory conditions for misreporting are unproved, the enhanced penalty is unsustainable.

Contractual recruitment and training services rendered to an insurance company are business-support activities rather than services in a profession enumerated or notified under section 44AA(1). Knowledge, skill or training involved in delivering those services does not by itself make them technical consultancy or professional services. Where the provider neither conducts insurance agency business nor earns commission or brokerage, the resulting receipts are business receipts eligible for the business presumptive-tax regime, subject to its statutory conditions, rather than the regime for specified professions.

Net-profit estimation at 8% in a best-judgment assessment was unsustainable because neither that rate nor the initially adopted 12% rate rested on the taxpayer's past history or comparable businesses. Absence of accounts and non-compliance with information requests may justify estimating business profit, but the estimate must be bona fide, rational and non-capricious. Profit must be redetermined using past history or comparables after a hearing.

Automated subscription, training and support services do not constitute fees for technical services under Article 12(5)(b) of the India-Netherlands tax treaty or section 9(1)(vii) of the Income-tax Act where they merely provide access to software systems. The make-available requirement is not met when software is hosted outside India, no unrebutted evidence establishes human intervention, and the recipient receives only a standard facility and a right to use the systems. Training and support limited to system use, without transfer of underlying technology or capability for independent future application, likewise do not transfer technical knowledge, skill, know-how or processes.

Corporate insolvency proceedings give finality to claims admitted under an approved resolution plan and extinguish excluded statutory dues, preserving a clean slate for the corporate debtor or resolution applicant. Where the successor entity has entered liquidation after failure to implement the approved plan, and no departmental tax claims for earlier assessment years were admitted in either the resolution or liquidation process, those claims cannot be pursued through connected income-tax appeal proceedings.

Section 147 permits assessment of income discovered during reassessment only after the Assessing Officer assesses or reassesses the income forming the recorded basis for reopening. The expression "and also" operates cumulatively, and Explanation 3 does not remove that substantive condition. Where no addition or adverse finding is made on the share-transfer issue recorded for reopening, an unrelated addition for unexplained cash credit cannot be sustained in that reassessment. A fresh notice under Section 148 is required to pursue the unrelated income; otherwise, the reassessment is without jurisdiction and void.

Interest earned by a primary agricultural credit co-operative society on its own funds temporarily or statutorily invested with banks is attributable to its credit-facility business and qualifies for deduction under section 80P(2)(a)(i), provided the funds are not liabilities payable to members. The wider expression "attributable to" covers income having a business nexus, unlike the narrower "derived from" standard. Provisions for interest payable and audit fees are allowable business expenditure where they represent accrued, quantified liabilities connected with the business rather than contingent obligations. Taxable income requires recomputation after granting the eligible deduction and allowing those accrued liabilities.

Reassessment for alleged escaped income requires the Assessing Officer to identify the proposed addition in the notice under Section 148A(b), obtain prescribed approval, consider the taxpayer's response, and issue an order under Section 148A(d) before reopening. Where a proposed cash-deposit addition was considered and dropped after accepting the explanation, a later cash-deposit addition not identified in the notice or statutory order and lacking specified-authority approval failed to satisfy the mandatory procedure. The unsupported reassessment addition was therefore deleted.

Reassessment based on Investigation Wing information identifying accommodation entries can rest on tangible material where it is verified against financial records and an independent satisfaction of income escapement is recorded; this avoids borrowed satisfaction. Cash-credit additions require proper examination of lenders' confirmations, tax returns, financial statements and bank records to establish identity, creditworthiness and genuineness. Non-response to information notices alone does not dispense with that examination. Claimed lender declarations and related tax payments under the Vivad Se Vishwas Scheme require verification before determining the unexplained-credit issue.

The enhanced leave-encashment exemption ceiling under section 10(10AA)(ii) was set at Rs. 25 lakh with effect from 1 April 2023. Certification that the notification would not adversely affect any person supported application of the revised ceiling to non-government employees who retired before the notification was issued. Consistent application of the enhanced limit to similarly placed pre-notification retirees supported exemption for leave encashment up to the revised ceiling.

Section 14A read with Rule 8D does not permit disallowance of expenditure where no exempt income was earned, received, or receivable during the relevant previous year. For assessment year 2017-18, the absence of exempt income precluded any disallowance under these provisions, consistent with the binding jurisdictional position.

Reassessment initiated more than three years after the relevant assessment year requires escaped income meeting the statutory threshold. Although the order under Section 148A(d) alleged escaped income above INR 50 lakh, the final reassessment addition, computed at 2% of alleged accommodation entries, was INR 24,21,552. As the final addition fell below the applicable threshold under Section 149(1)(b), the reassessment proceedings and reassessment order were invalid and quashed.

Section 147 reassessment cannot rest solely on material already examined during a completed scrutiny assessment under Section 143(3). Where financial statements and furnished particulars were considered in the original assessment, reopening based only on the existing assessment record constitutes a change of opinion rather than a valid reason to believe that income escaped assessment. Fresh tangible material obtained after completion of the original assessment is required to support such reassessment; absent it, the reassessment proceedings are invalid and liable to be quashed.

Section 69A additions for jewellery require evidence beyond an ad hoc estimate. Customary ownership, including married daughters' streedhan retained at the parental home, may be established through affidavits, marriage photographs and applicable CBDT jewellery-holding guidance. Without departmental inspection, valuation, or cogent material connecting jewellery to undisclosed income, an addition is unsustainable. Likewise, documented bank withdrawals exceeding cash found can establish its source, preventing an unexplained-cash addition. Credible evidence of ownership and source therefore defeats unexplained-assets additions lacking contrary material.

Section 43B(d) requires actual payment for deduction of specified interest, but interest liability converted into cumulative redeemable preference shares under a corporate debt restructuring arrangement did not warrant disallowance. The applicable High Court precedent retained binding force because a pending special leave petition, without a Supreme Court stay, reversal, or modification, did not displace it. Consequently, the disallowance relating to the converted interest liability was deleted.

Settlement immunity under the Income-tax Act cannot extend to a prosecution instituted before the settlement application, even where the tax liability is resolved. That statutory bar does not displace inherent criminal jurisdiction to assess whether continuation of prosecution is justified. Where a settlement order is final, liabilities have been paid, no breach or challenge exists, and proceedings have remained pending for many years, continuation may serve no meaningful penal purpose and amount to abuse of process. The criminal complaint, summoning and consequential proceedings were quashed.

Section 127 requires recorded reasons for a transfer of jurisdiction and, where feasible, an opportunity of hearing; the hearing requirement is relaxed for transfers within the same city, locality or place. Following search-related group centralisation, assessees who sought or knew of centralisation, filed returns and participated before the transferee officer without timely objection may be treated as having waived technical natural-justice objections. Challenges concerning assessment notices, opportunity, and additions should ordinarily use the statutory appeal mechanism rather than writ jurisdiction where that remedy is effective. Group centralisation consequently remains operative, with assessment challenges to be pursued through statutory appeals.

Taxability of non-compete consideration was governed by an existing binding determination on corresponding receipts. Because the consideration fell within that established treatment, uniformity required the same tax result. The addition relating to the non-compete fee was therefore unsustainable and was deleted, with the substantial questions resolved in favour of the assessee.

Transfer-pricing comparability under Rule 10B requires assessment of market conditions, assets employed and risks assumed. As the Rules prescribe no statutory upper or lower turnover threshold, an upper turnover filter of Rs. 200 crore can be applied as a rational factual benchmark for determining the arm's length price. Interference with that comparability determination requires a specific showing of perversity. Application of the Rs. 200 crore upper turnover filter was treated as valid in the assessee's transfer-pricing analysis.

FCRA appeals against refusal of registration are to be heard by a Division Bench because they are treated like appeals from original decrees and lack monetary valuation. Rule 9 requires Form FC-3A applicants to accurately disclose whether their character is religious, including the applicable religious classification. Zen Buddhist philosophy is religious; describing a religious organisation as non-religious while conducting religious programmes constitutes material misrepresentation and may justify refusal. Sections 11 and 12 do not absolutely bar religious organisations from registration, but registration is discretionary rather than vested. Educational or cultural instruction differs from worship and rituals, while conversion-related activities are statutorily prohibited. Discretion remains reviewable for illegality, perversity, non-application of mind, or disregard of relevant material.