A separate DIN-bearing intimation that identifies the DIN of enclosed DRP directions satisfies traceability requirements despite the directions themselves lacking a DIN; retrospective validation provisions also prevent invalidation where the assessment order is identified by DIN. Following a remand requiring verification and hearing, assessment must comply with the limitation applicable to giving effect to an appellate order. A remand for recomputation of arm's length price does not constitute a fresh transfer-pricing reference based on the Assessing Officer's fresh satisfaction and cannot trigger the additional limitation extension. Expiry of that period renders the consequential assessment unsustainable.

Denial of exemption under Section 11 does not permit automatic taxation of an entity's entire gross receipts. Exemption eligibility and income computation are distinct: where exemption is unavailable, taxable income must still be determined under the applicable provisions on a real-income basis. Unless a specific provision requires gross-basis taxation, legitimate expenditure incurred to earn the receipts must be verified for its nature, genuineness and legal admissibility, then allowed in computing net taxable income.

Rule 87 sets the ceiling for annual employer contributions to an approved superannuation fund and cannot cap contributions to a recognised provident fund. Employer provident-fund contributions above 12% may be taxable as salary for employees, while the employer's deduction remains conditional on actual payment under Section 43B. Business expenditure must be proved as incurred wholly and exclusively for business; incomplete, self-made, or unverifiable vouchers may support a reasonable ad hoc disallowance. Illness of the person responsible for tax, finance, and legal matters may constitute sufficient cause for delay where supported by medical evidence.

Faceless assessment communications between the Assessment Unit and Technical Unit must pass through the National Faceless Assessment Centre; an email to the assessee with the centre copied does not establish prescribed receipt by the Assessment Unit. Time taken from a valuation reference until receipt of the valuation report is excludable in computing the assessment limitation period, with the remaining period extended where applicable. Once stamp duty value is disputed and a statutory valuation reference is made, the Assessing Officer must conform to the Valuation Officer's estimate and cannot replace it with stamp duty value. Valuation must be redetermined using appropriate comparables and relevant property-specific evidence.

Registration of a trust cannot be rejected on adverse verification findings without confronting the trust with that material and providing an effective hearing. Donations and expenditure reflected in financial and activity records do not, by themselves, establish that the trust has not commenced activities. The registering authority must independently verify whether activities are carried on and examine their genuineness. A fresh registration application remains permissible after activities commence despite an earlier unappealed rejection, as no statutory bar prevents a further application. The rejection was quashed, requiring fresh adjudication after due opportunity of hearing.

Compulsory-acquisition compensation awarded under the 2013 land-acquisition framework before 31 December 2014, but remaining unpaid until receipt in financial year 2015-16, qualifies for income-tax exemption under Section 96. The exemption extends to the compensation amount and prevents its assessment as long-term capital gains. Separate interest received on compulsory-acquisition compensation retains an independent taxable character and is assessable as Income from Other Sources under Section 56(2)(viii) of the Income-tax Act, 1961.

Section 68 requires the nature and source of each credit to be established through supporting evidence. Non-response to information notices is not conclusive where confirmations, banking records, repayment evidence, or other substantive material supports the credit, and credits from an earlier year should not be assessed in the relevant year. Taxability of a sale receipt requires verification of whether it was already offered to tax. Corpus and purchaser-related deposits cannot be treated as unexplained income merely because they are recorded as liabilities or retained; purchaser-wise agreements, ledgers, receipt modes, and subsequent treatment require examination. Unsupported notional-interest additions cannot substitute for evidence of actual income.

Shares received by gift and taxed on their fair market value retain their character as gifts; the previous owner's holding period is included when determining whether they are long-term capital assets. Taxation of the gift value changes the statutory cost of acquisition, not the holding-period rule. The deemed cost, being the value subjected to tax, qualifies for indexation when computing long-term capital gains. However, indexation applies only from the financial year in which that deemed cost arose through taxation, rather than from the period during which the previous owner held the shares.

Cash deposits made during demonetisation were examined under the unexplained cash-credit rule. Cash books and VAT records supported regular sales activity, and cash held before demonetisation was attributable to prior sales. Depositing that cash subsequently in bank accounts did not make its source unexplained. The deposits were treated as satisfactorily explained, requiring deletion of the addition under section 68.

Cash received and temporarily held for safe custody by a mediator in a property transaction does not constitute acceptance of a loan or deposit for section 269SS. Where affidavits, a registered sale deed and bank records establish that the amount was deposited into the mediator's bank account and promptly paid to the seller by cheque, the receipt falls outside the statutory prohibition. Alternatively, the bona fide nature of the arrangement constitutes reasonable cause under section 273B. Penalty under section 271D is therefore unwarranted and liable to be deleted.

Section 144C(13) requires a final assessment order following DRP directions to be completed within one month from the end of the month in which the directions are uploaded. Directions uploaded on the ITBA portal on 29 September 2021 required completion by 31 October 2021. A final assessment order passed on 24 November 2021 exceeded that statutory period, rendering it time-barred, void and set aside.

Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for conducting its business; group-wide filings and website information do not suffice. Dependent agency permanent establishment requires material showing that the subsidiary habitually concludes contracts, maintains and delivers stock, or habitually secures orders for the foreign enterprise. An independently operating manufacturer dealing on a principal-to-principal basis and bearing business risks does not satisfy these conditions. A royalty licensing arrangement does not establish agency for distinct offshore supply transactions. No profits from those supplies are attributable in India absent either form of permanent establishment.

Mandatory reversal of common GST input tax credit attributable to unsold units at Building Use Permission is treated as an irrecoverable project cost when post-completion sales fall outside output GST. Project-wise credit apportionment requires final adjustment by reference to the unsold portion, and the absence of fresh cash payment does not prevent deduction where a previously valid credit becomes unusable by law. The deduction arises in the assessment year when final statutory attribution crystallises, rather than earlier years when the credit remained available. A related reversal claim requires verification and must be allowed in only one appropriate assessment year to prevent double deduction.

Interest and other income earned by a co-operative society through deployment of funds not immediately required for member lending fall within income attributable to its business of providing credit facilities to members. The broader expression "attributable to", unlike "derived from", supports full deduction under Section 80P(2)(a)(i). Interest on amounts retained and payable to members is distinguishable because it arose in a different factual setting involving a claim under Section 80P(2)(d).

Section 87A rebate is available for assessment year 2024-25 against tax payable on long-term capital gains taxable under section 112, provided the prescribed total-income condition is met. Total income includes such gains, and neither section 87A nor section 112 expressly excludes the rebate for income taxed at that special rate. The specific exclusion in section 112A for certain gains does not extend to section 112 gains. The Finance Act 2025 restriction on rebate for income taxable at special rates is substantive and operates prospectively, so it does not affect assessment year 2024-25.

Revenue deductibility of Bio-Pharma Division expenditure depends on whether the business had been set up and was ready to perform its intended functions, rather than solely on the later commencement of commercial operations. Annual-report evidence of completion of the first project phase and commencement of production supports that status; later financial-enforcement events and uncertain segment-turnover allocation do not negate it for the relevant year. Blanket capitalisation of all divisional expenditure is inappropriate, since depreciation, interest on borrowed capital and scientific-research expenditure must independently satisfy their statutory conditions. On these facts, the full capital disallowance was unsustainable and deleted.

Section 68 treatment of share-capital and share-premium credits turns on evidence of the source, investor identity, creditworthiness and transaction genuineness. An accepted Income Declaration Scheme declaration may evidence the source of credited funds without conferring derivative immunity, and re-taxing income already taxed in the declarant's hands raises double-taxation concerns. For assessment year 2011-12, the later source-of-source proviso did not apply to closely held companies; however, fund trails suggesting circular routing of the assessee's own funds or cash-funded investor entities require verification. Reassessment may rest on specific search material establishing reason to believe, rather than borrowed satisfaction, even without a separate speaking order on objections.

Returns furnished in response to notices under section 148 issued before 1 April 2023 retain the character of returns required under section 139. The later third proviso to section 148, which denies that treatment to returns filed beyond the permitted period, does not apply to an earlier notice. Where a delayed return is filed during pending reassessment proceedings and is acted upon in computing assessed income, notice under section 143(2) remains mandatory. Non-issuance of that notice constitutes a jurisdictional defect rather than a curable procedural irregularity, rendering the reassessment invalid.

Capital-gains computation permits transfer brokerage and actual property-improvement costs where receipts, invoices or objective property records substantiate the expenditure. Non-retention of every invoice, particularly by non-resident owners, does not by itself justify rejecting otherwise supported improvement costs. For residential-property exemption purposes, a mandatory corpus-fund payment intrinsically linked to ownership forms part of the cost of the new property. Supplier invoices and payment receipts may establish qualifying expenditure even without a corresponding bank statement, absent contrary material. Labour and painting claims lacking identifiable bills, receipts or other reliable proof remain inadmissible. Capital gains and consequential exemption require recomputation after allowing substantiated expenditure and excluding unsupported claims.

Section 144C applies where an Assessing Officer proposes a variation in returned income through a draft assessment order on or after 1 October 2009, irrespective of the assessment year. For a remand requiring fresh adjudication by the DRP rather than consequential action, the fresh-assessment limitation falls under section 153(2A). Where a fresh transfer-pricing reference is made, the fourth proviso allows two years, running from departmental receipt or knowledge of the appellate order; internal movement or delayed receipt by the particular DRP does not defer it. Section 144C(13) regulates orders following DRP directions but does not displace section 153(2A)'s limitation, rendering proceedings after expiry unsustainable.