Sanction for reassessment beyond three years under section 149(1)(b) required valid approval. The approval proforma placed the proceedings within the period exceeding three years but not exceeding ten years, while the approval was granted by the PCIT. Applying a materially similar High Court ruling, ITAT treated the approval as invalid, quashed the section 148A(d) order, section 148 notice and consequential assessment, and left the remaining grounds open as academic.

Revision under section 263 may apply where reassessment of alleged bogus purchases lacks requisite verification. Supplier non-response, failure to furnish requested confirmations, evidence of goods movement and transporter payments, and the Assessing Officer's failure to undertake follow-up inquiry indicate inadequate inquiry. Mere issuance of notices and receipt of partial material do not constitute an inquiry reaching a conclusion under Explanation 2(a). An unreasoned profit-rate estimate does not represent a legally sustainable plausible view or a concluded opinion protected by change-of-opinion principles, rendering the assessment erroneous and prejudicial to the interests of the Revenue.

Tax deduction at source under section 194H requires the assessee to make a commission payment within a principal-agent relationship. Where a principal directly credits retailer incentives and deducts tax under the intermediary's PAN, the intermediary's recording of gross receipts and retailer shares for Form 26AS reconciliation does not establish receipt of that share as income or a separate payment from its own funds. Trade incentives or discounts in principal-to-principal transactions therefore do not attract the withholding obligation or consequential disallowance.

Disputed stamp-duty valuation for property purchased requires the Assessing Officer to obtain a Valuation Officer's determination of fair market value before sustaining an addition under section 56(2)(vii). The valuation issue requires fresh examination of a co-owner's valuation report, its applicability, and the taxpayer's objections, with an opportunity of hearing. Claimed agricultural income likewise requires reconsideration against evidence of landholding and agricultural activity. Both the property-valuation addition and the characterisation of agricultural income require fresh adjudication rather than determination on the existing record.

Locus standi prevents an erstwhile director from prosecuting an appeal on behalf of a struck-off company that did not represent itself before the assessing or first appellate authority. A pre-emptive assessment made to protect Revenue against statutory limitation is not invalid solely because the company is non-existing. The former director may challenge personal liability only in proceedings under section 179; accordingly, the appeal on the company's behalf was dismissed.

Revision for alleged lack of inquiry into depreciation on toll-collection and sea-link operation rights was unsupported where the assessment record contained notices, details of the intangible-asset investment, the concession agreement and the depreciation claim. CBDT Circular No. 9/2014 concerning expenditure incurred by a BOT road or highway developer did not apply to a non-developer concessionaire that acquired toll-collection, operation and maintenance rights. As the cost was deductible through either depreciation or amortisation, the difference concerned timing and caused no real prejudice to revenue. The revision was quashed and the original assessment restored.

Rent paid to a related party for corporate office premises was treated as allowable business expenditure because the premises were used for business. Consistency in income-tax assessments applied where the relevant facts matched the preceding year and no distinguishing material was produced. The earlier acceptance of the rent claim was followed, resulting in deletion of the rent disallowance and dismissal of the Revenue's appeals for the relevant assessment years.

Interest on time deposits paid by a co-operative bank to a non-member co-operative society falls within the second limb of the TDS exemption for payments to co-operative societies. Although the member-payment limb specifically excludes co-operative banks, that exclusion does not extend to the separate limb for payments to another co-operative society. The bank retains its legal character as a co-operative society for this purpose. Accordingly, no tax deduction at source is required, and TDS-default and consequential interest liabilities do not arise.

Electronic evidence in income-tax assessments is not automatically inadmissible for lack of an Evidence Act certificate or non-compliance with the Digital Evidence Investigation Manual, although authenticity and probative value require factual scrutiny. Search statements are relevant but require corroboration where credibly disputed; necessary cross-examination safeguards against additions based solely on untested admissions. Student-wise reconciliation and contemporaneous books may rebut alleged unaccounted institutional fees, while refundable caution deposits remain liabilities rather than income. Site-imprest payments through authorised agents may fall within Rule 6DD(k). Charitable application depends on purpose and end-use, not vendor .....

Extended limitation for customs duty recovery under Section 28(4) requires material showing suppression, wilful misstatement, or another statutory basis. Where an importer supplied the SAFTA certificate of origin and other clearance documents, alleged defects in the certificate did not by themselves establish suppression. Proceedings initiated nearly five years after clearance lacked evidentiary support for invoking the extended period. The concurrent conclusion rejecting the extended limitation was maintained, and the Revenue's appeal was dismissed.

Cognizance for alleged non-cooperation with a Companies Act investigation is assessed solely from the complaint and supporting materials to determine whether they disclose a prima facie offence. Where those materials identify the alleged offence and demonstrate application of mind, explanations and documents relied on by company directors are defence matters for trial. Considering them at the cognizance stage would improperly conduct a mini-trial. Cognizance and process therefore remained operative, with defences reserved for trial.

Section 29 of the National Green Tribunal Act bars civil-court jurisdiction only for matters within the Tribunal's statutory jurisdiction under Schedule I enactments. Boundary fixation and lateral-support claims based on proprietary and easement rights, including rights under the Indian Easements Act, fall outside that framework and remain maintainable before civil courts under the general civil jurisdiction preserved by the Code of Civil Procedure. Article 227 supervisory jurisdiction cannot be used to secure rejection of such a plaint or bypass remedies available before the trial court when no complete statutory bar exists.

Conflicting coordinate Bench interpretations of the Customs Tariff Act govern whether breach of the pre-import condition under an advance authorisation exemption attracts IGST interest, fine and penalties. Neither view is treated as per incuriam because each independently construed the relevant provisions and legal position. The conflict creates uncertainty for identical future matters, requiring a uniform determination by a Larger Bench. The appeals are to be placed before the President for possible constitution of a Larger Bench; liability to interest, fine and penalty remains undecided.

Mandatory prior approval from the competent authority is required before issuing a reassessment notice. Where the required approval is absent, reassessment proceedings suffer from a jurisdictional defect and are void ab initio. A revision order cannot validly rest on an invalid reassessment, and any consequential assessment founded on that revision similarly lacks legal basis and is unsustainable.

Customer advances adjusted against subsequent recorded sales should not be separately treated as unexplained cash credits where sales turnover and quantitative stock records are undisputed, because this would duplicate income already offered to tax. Delayed inability to obtain customer confirmations does not change that result. Alleged sales suppression cannot rest solely on differences between average purchase and selling prices, particularly for perishable goods sold at negotiated lower prices. Without disputed stock records, concrete enquiry, corroborative material, or identified unrecorded sales, estimated additions for suppressed sales are unsustainable. The stated principle bars additions duplicating recorded trading results or based only on uncorroborated price averages.

Penalty for furnishing inaccurate particulars under Section 271(1)(c) cannot stand where it rests solely on a quantum disallowance that has been deleted in appellate proceedings. The penalty had been imposed consequentially upon disallowance of forward cover premium under Section 37(1). Deletion of that quantum addition removed the foundation for the penalty, resulting in deletion of the penalty in favour of the assessee.

Section 69 permits an addition for unexplained investment only where the taxpayer fails to establish the investment's source. Investment in agricultural land was satisfactorily explained through accepted contractual receipts and agricultural income, supported by the land agreement, cash book, cash-book summary, and contractual-receipt details. Treating the investment as unexplained despite this supporting material being on record was inconsistent with the factual record. The addition for unexplained investment was therefore unsustainable and required deletion.

Cash deposits were treated as explained where bank statements substantiated the mother-in-law's withdrawals, the preceding bank credit arose from a land-sale agreement, and the amount was returned by cheque on the same day. The remaining deposit was supported as a gift from the wife, a regular income-tax return filer. No material established that the repayment was undisclosed on-money for a later property purchase. Accordingly, the deposits' source and genuineness were established, and the addition for unexplained investment based on surmises and conjectures was deleted.

Third-party diary notings lacking dates, the taxpayer's name, and corroboration do not substantiate unexplained-expenditure or election-expenditure additions. Deleting an alleged payment entry while introducing a separate stamp-paper-purchase addition without an enhancement notice raises a distinct procedural defect. Where the taxpayer neither admits election expenditure nor independent material supports it, the addition lacks an evidentiary basis. On these facts, the combined additions were treated as unsustainable and deleted.

Penalty under Section 271(1)(c) requires satisfaction on concealment or inaccurate particulars to be recorded during the original assessment proceedings. Where no satisfaction was recorded for particular disallowances, a later endorsement in a giving-effect order cannot validate penalty; penalties on those additions were therefore unsustainable. Foreign-exchange loss accounted for under Accounting Standard-11 need not form part of inventory cost under Accounting Standard-2 where a recognised contrary view exists. As the resulting closing-stock valuation issue was debatable, the treatment did not establish inaccurate particulars, making the related penalty unsustainable.