Pre-sampling mixing of contraband recovered from separately seized packets conflicts with prescribed seizure and sampling safeguards. Separate packages or containers must be individually weighed and serially numbered, and samples must be drawn from each packet or container. Where contents are identical, representative quantities may be combined only through the prescribed inventory and sampling process in a Magistrate's presence. Immediate mixing at the seizure stage is prima facie impermissible and constitutes a substantive breach rather than a minor procedural irregularity. Non-compliance with mandatory seizure and sampling requirements may undermine the prosecution case and support entitlement to regular bail.

Separate memoranda of appeal are required where a common judgment both dismisses a suit and allows a counterclaim. Failure to file separate memoranda is curable if the composite appeal was timely and otherwise free of serious defects. Procedural rules allow dispensation with a duplicate judgment copy in specified circumstances. Courts should permit rectification before technical rejection, preserving determination on merits.

Cash gifts from the assessee's mother and brother were not unexplained cash credits where donor identities, PANs, income-tax returns, regular income sources, and evidence of advances under agricultural-land sale agreements established the nature and source of the gifts. For assessment year 2018-19, Section 68 did not require the assessee to establish the source of the donors' funds, because that requirement applied only from assessment year 2022-23. The gifts were therefore satisfactorily explained and could not be assessed under Section 68.

Section 69 applies only to unexplained investments made during the relevant year; deposits evidenced as pre-existing opening balances fall outside its scope. Financial extracts drawn from accounting records seized during search are not fresh additional evidence under Rule 46A where the underlying records were already available and the figures remain undisputed. Section 69C requires proof that expenditure was actually incurred, not merely that liabilities were recorded as payable. Interest on unrecoverable loan principal is hypothetical rather than real income, and income must be assessed in the hands of the person or entity to whom it belongs.

Additional evidence comprising shipping and banking records may be admitted where necessary for proper determination of unexplained Customs-duty expenditure and capital-credit additions; those additions require fresh factual adjudication after hearing. Interest on fixed deposits pledged as margin money for business credit facilities has a direct business nexus and is assessable as business income rather than income from other sources. Export sale proceeds and export incentives cannot be treated as bogus or unexplained solely on investigative show-cause material where export and banking evidence supports the transactions. Overseas customer advances received through banking channels are not unexplained credits once party particulars and receipt evidence discharge the taxpayer's burden, absent Revenue rebuttal or available verification.

Cash deposits made during demonetisation are not unexplained cash credits where recorded cash sales are supported by the cash book, sales ledger, stock register, VAT returns and audited accounts, and sufficient cash balances existed on the demonetisation date. Where sales and book results remain unrejected and revenue identifies no discrepancy between sales and VAT returns, assumptions about cash retention or business practices cannot displace documentary evidence. Cash sales of a newly commenced unit cannot be benchmarked against a prior year in which it was not operating.

Unexplained cash-credit addition under section 68 depended solely on directors' statements admitting accommodation entries. Statements unaccompanied by relevant corroborative evidence were insufficient to sustain the addition. The earlier larger addition had been deleted in principle during remand proceedings. The remaining disputed addition was therefore deleted in favour of the assessee, removing the residual section 68 liability.

Section 68 of the Income-tax Act requires proof of a creditor's identity, transaction genuineness and creditworthiness. PAN details, confirmation, bank records and financial particulars may discharge the assessee's initial burden; the evidentiary burden then shifts to the Revenue to produce contrary material before an unsecured loan can be treated as unexplained cash credit. Agricultural receipts supported by labour-payment records, input bills and sale bills require factual verification where those materials were not examined by lower authorities. Such evidence may be admitted under Rule 29, with de novo examination needed to reconcile claimed receipts and computed income consistently with natural justice.

Rule 11UA(2) permits valuation of unquoted equity shares through either the prescribed formula-based method or the Discounted Cash Flow method. Where the Discounted Cash Flow method is validly selected, valuation scrutiny, including independent revaluation, must remain within that methodology; the Net Asset Value method cannot replace it. Projections, discount rates and terminal values must be assessed using material available on the valuation date rather than subsequent actual results, and the assessee must substantiate valuation inputs. Earlier non-addition or subsequent return processing without scrutiny does not establish consistency protection against examination of share-premium valuation.

Registration of a charitable trust under section 12A(1)(ac) cannot be refused solely on an alleged claim of exemption under section 11 where the relevant returns demonstrate that no such claim was made. Exemption claimed under section 10(23C)(iiiad), coupled with the furnishing of required records, operation of educational institutions and other charitable activities, supported eligibility for registration. The activities fell within charitable purpose, and their genuineness was not doubted; registration was consequently to be granted.

Section 270A requires the competent authority to direct, during proceedings under the Income-tax Act, that a person is liable to penalty for under-reporting income. Neither the assessment order nor the consequential order giving effect to the appellate order recorded initiation of penalty proceedings. An appellate observation that proceedings had been initiated was factually incorrect. In these circumstances, the penalty order was void ab initio and the penalty was liable to be deleted.

Reassessment notices for assessment years up to 2021-22 remain governed by the earlier limitation period under the first proviso to section 149(1)(b); accordingly, a notice for AY 2015-16 issued after expiry of its six-year period is time-barred, rendering the consequential section 147 assessment unsustainable. Where a notice for AY 2016-17 is issued more than three years after the end of that year, section 151(ii) requires prior approval from the Principal Chief Commissioner or another specified authority. Approval from a Principal Commissioner is insufficient, invalidating the reassessment and consequential assessment.

Reassessment proceedings initiated against a company dissolved through amalgamation before the notice was issued are jurisdictionally defective where the Assessing Officer had been informed of the amalgamation. A notice issued to the non-existent entity, and the consequential assessment, are void ab initio. A best-judgment assessment cannot cure this foundational defect, so reassessment proceedings cannot be sustained against the dissolved company.

Registration under section 12AB depends on satisfaction as to an entity's objects and the genuineness of its activities, supported by documents prescribed under Rule 17A(2). Non-compliance with electronic notices may warrant fresh consideration where an unrebutted affidavit establishes a bona fide inability to access them, including because of a trustee's age, health or absence. The registration application is to be reconsidered after the applicant furnishes the requisite documents and complies with notices.

Section 14A read with Rule 8D(2)(iii) requires the administrative-expense disallowance to be computed using the average value of investments that actually yielded exempt income during the relevant year. Including all investments shown in the balance sheet, irrespective of whether they generated exempt income, is inconsistent with this approach. The disallowance should therefore be recomputed by excluding investments that did not yield exempt income during the year.

Cash deposits stated to represent turnover from an eligible food-grain business were considered under the presumptive taxation framework rather than as unexplained investment. Where comparable turnover in the succeeding year had been accepted for presumptive computation and turnover was not questioned for either year, income was computed at the 8% presumptive margin. This treatment replaced the unexplained-investment addition and produced income below the taxable threshold on the stated facts.

Cash deposits comprising specified bank notes are not assessable as unexplained money under Section 69A where customer collections for electronic-payment facilitation are supported and their source is explained; dealings before 31 December 2016 were not prohibited. Bank credits demonstrably attributable to another taxpayer's money-transfer business, where related commission has been taxed there, must be excluded to avoid double taxation. Commission for the taxpayer's own electronic-payment facilitation business is to be computed at the evidence-supported 2.5% rate rather than 8%, with eligible TDS credit.

Industrial Promotion Assistance granted for capacity expansion, modernisation and marketing improvement is characterised under the purpose test by its object rather than its sales-tax-based quantification; it is therefore a capital receipt outside taxable income. Railway-siding costs are revenue expenditure where the taxpayer does not own the sidings, subject to confirming that depreciation has not been claimed. Where own funds cover investments, no interest disallowance arises for exempt-income investments. Indirect-expenditure disallowance is confined to investments that actually generated exempt income during the relevant year.

Pre-reassessment procedure requires a show-cause notice to provide at least seven and no more than thirty days for a response. A notice allowing six days does not meet the statutory minimum, which operates as a due-process safeguard. The jurisdictional determination to issue a reassessment notice must also be a reasoned speaking order that considers the available material and the assessee's response. A blank determination contains neither a decision nor reasons and cannot support reassessment jurisdiction or consequential assessment proceedings.

Recorded bullion-sale cash deposits during demonetisation were explained where regular cash books, sales registers, stock records, audited accounts, purchase records and VAT returns substantiated the sales, and neither stock movement nor sales disclosures were disputed. Section 69A did not apply because sale proceeds already recorded, credited and offered to tax could not be reassessed as unexplained money without double taxation. Unsupported suspicion concerning the timing or volume of sales could not override the documentary trail establishing the source of deposits. The unexplained-money addition was deleted.