Circumstantial evidence can sustain murder, conspiracy and destruction-of-evidence convictions only when the proved circumstances form a complete chain excluding every reasonable hypothesis of innocence. Electronic communications may be authenticated through certificates and responsible service-provider testimony despite non-prescribed certificate formats or authorised data transfers. Discovery pursuant to disclosure statements, deleted communications, unexplained contact patterns, conduct and false alibis may complete that chain. Article 161 clemency remains a distinct constitutional power, wider than statutory remission, permitting individual pardon, reprieve, remission or commutation on ministerial advice and unaffected by statutory remission mechanisms.

Documented cash purchases of fruits supported by ledger accounts, sale invoices and bank-account extracts constitute explained business expenditure where the supplier dealings are regular, and corresponding receipts and transactions have been disclosed. Failure to give due cognisance to this evidence cannot sustain an addition for unexplained expenditure under Section 69C. The expenditure is treated as arising from disclosed business transactions rather than unexplained spending.

Cash deposits in a taxpayer's bank account were explained as consultancy fees collected from identified clients and already included in gross receipts reported in the income-tax return. Cash vouchers recorded the clients and amounts collected, providing documentary support for the deposits' source. Because that evidence was not rebutted, the deposits could not be sustained as unexplained, and the corresponding addition was deleted.

Penalty for under-reporting of income under section 270A was unsustainable where the assessment order initiated penalty proceedings under section 271(1)(c), an inapplicable provision for the relevant assessment year beginning on or after 1 April 2017. Initiation under the obsolete provision demonstrated non-application of mind and vitiated the penalty proceedings at their foundation. Consequently, the penalty levied under section 270A was deleted.

Presumptive-tax addition based on bank credits required examination of the bank statements and ledger accounts reportedly filed in appellate proceedings. Although the appellate order recorded that no evidence supporting the bank deposits had been filed, it also reproduced the taxpayer's submission that bank-account statements and ledger-account copies were enclosed. Verification of the underlying deposits and a fresh determination of the addition were required, after affording the taxpayer an opportunity of hearing.

Fresh opportunity of hearing was granted for reassessment of cash deposits during demonetisation, estimated business income and disallowed salary-related claims. The assessee had not assisted during the assessment or first appellate proceedings; a further opportunity was therefore permitted to substantiate the claims through written submissions and documentary evidence. The assessment was remanded for fresh adjudication after a hearing, without determination of the merits of the additions or claims.

The 25% corporate tax rate for Assessment Year 2018-19 applied where a company's total turnover in the previous year 2015-16 remained below Rs. 50 crore. Total revenue of Rs. 48.72 crore, comprising Rs. 46.79 crore from operations and Rs. 1.93 crore as other income, remained within that threshold. The company was consequently subject to tax at 25% rather than 30%.

Revisionary jurisdiction under Section 263 requires a demonstrated error in the assessment order that is prejudicial to Revenue interests. Where the taxpayer has furnished complete particulars of legal and professional expenses, including their nature and purpose, and the assessment follows adequate enquiry, a revisional authority must identify a specific defect and explain the resulting prejudice. The power cannot be invoked merely to seek further verification or to conduct a fishing and roving enquiry. On these stated facts, revision of the assessment concerning the expense allowability was unjustified.

Interest awarded under section 28 of the Land Acquisition Act forms part of enhanced compensation and, unlike section 34 interest for delayed payment, does not become income from other sources. Amendments governing taxation of compensation interest do not alter that character. Revisionary jurisdiction under section 263 is unavailable where the Assessing Officer specifically examined the issue and adopted a legally possible view on a debatable question. An audit objection alone cannot render the assessment erroneous and prejudicial to the Revenue, while an unreasoned dismissal of a special leave petition is not binding law.

Section 153C treats the date on which seized material is handed over to the jurisdictional Assessing Officer and satisfaction is recorded as the deemed search date for applying the six-year assessment block under Section 153A. Where handover occurred during financial year 2021-22, only assessment years 2016-17 through 2021-22 fell within the assessable block. Assessment year 2015-16 therefore lay outside the prescribed period, rendering proceedings for that year time-barred and beyond jurisdiction.

Additions for unexplained cash credits in a concluded, unabated search assessment require incriminating material actually found during the search. An investigation report alleging accommodation entries, or a statement recorded during search that is unsupported by seized material, does not meet that requirement. Expiry of the period for issuing a scrutiny notice means the assessment remains concluded; non-filing of the original return does not make it pending. Nor does a return filed in response to a search-assessment notice itself become incriminating material. Consequently, an unexplained cash-credit addition resting only on those sources is unsustainable and liable to deletion.

Recorded petrol and diesel sale proceeds, supported by unrejected books, stock availability and sales records, do not become unexplained cash credits merely because specified bank notes were accepted during demonetisation; taxing them separately would duplicate taxation of the reported profit. Customer advances supported by booking orders, invoices, affidavits, identity documents and ledgers cannot be treated as unexplained credits merely because partial receipts were not completed sales. Corroborative additional evidence relevant to those advances should not be refused where refusal would breach natural justice. Application of Section 68 requires the recorded receipts or supporting evidence to be discredited.

Section 148 permitted reassessment for the relevant assessment year within six years from its end where escaped income exceeded the prescribed threshold. A document seized from a person's custody attracts a statutory presumption of ownership and truth of its contents; the person must rebut that presumption with credible supporting material. Assertions that the seized document or transaction belonged to a family member require confirmation, disclosed returns, books of account, or other substantiating evidence. An assessment is not invalid merely on a Document Identification Number objection where departmental records comply with the applicable requirement.

Section 145(3) permits rejection of books of account where their correctness or completeness cannot be verified. Non-production of books, bills and vouchers, failure to comply with creditor-verification notices, and lack of documentary support for a substantial fall in the net-profit rate justified rejection. In the absence of material displacing these findings, the rejection of accounts and consequential net-profit addition were sustained.

Tax deduction at source obligations on interest, earthwork and transport payments do not arise where truck income was declared under presumptive taxation and, after excluding transportation receipts, no remaining turnover triggered tax-audit requirements. Consequently, expenditure disallowance for failure to deduct tax is unsustainable. Interest on property-backed borrowings used for business is not disallowable merely on an allegation of non-business diversion without concrete supporting material. Where own capital exceeds loans and advances, advances may be presumed to have been made from own funds, preventing interest disallowance.

Sale consideration received on a transfer of shares is not assessable as unexplained cash credit where its nature and source are satisfactorily established. Banking records supporting the share purchase, coupled with transaction documents for the sale, purchaser confirmation, and an affidavit furnished during verification, link the receipt to an identified and evidenced share transaction. The receipt is therefore fully explained and no addition for unexplained cash credit arises.

Section 153C provides the applicable non-obstante assessment procedure where incriminating material relating to an assessee is seized during a third-party search. It overrides regular assessment and reassessment routes, including sections 143(3), 147 and 148, where proceedings are founded on that material. An assessment initiated under section 143(3) on the basis of such third-party search material is therefore invalid and liable to be quashed.

Cash-deposit additions were not maintainable where AIR and CIB data duplicated transactions in the same bank account and audited records reconciled deposits with recorded petrol-pump sales and business receipts. A capital-account difference did not constitute unexplained cash credit where capital introductions, tax refunds and withdrawals reconciled the apparent mismatch. Gross commission could not be taxed without deducting substantiated business expenses, leaving only disclosed net commission income taxable. FD interest pledged for a bank guarantee and miscellaneous receipts already credited to the profit and loss account could not be separately assessed as income from other sources, as that would duplicate taxation.

Section 80IA(4C) covered undertakings commencing electronic data interchange services within the prescribed period. Eligibility did not require end-to-end telecommunications services or complete independence from existing infrastructure. A separate undertaking could be established through dedicated equipment and infrastructure, technical personnel, regular service provision, and separately identifiable profits; use of existing networks and cables did not defeat that status. Services commercially launched as electronic data-transfer services remained eligible electronic data interchange services despite later being described as internet services, applying substance over form. The undertaking's profits qualified for the deduction.

Section 11 exemption requires valid registration under section 12A or 12AB for the relevant assessment year; provisional registration effective only from a later year does not satisfy that condition. Where charitable exemption is unavailable, taxable income cannot be assessed on gross receipts alone. Income must be computed on ordinary commercial accounting principles after verification of expenditure incurred wholly and exclusively for earning the receipts. Legitimate verified expenditure must be allowed, and tax liability confined to the resulting net income, if any.