Section 271E penalty for alleged cash repayment of loans is unsustainable where a corrected auditor certificate and banking records establish that repayments were made through account-payee cheques, NEFT or RTGS. Erroneous tax-audit reporting alone does not establish a contravention of Section 269T when no loan transaction occurred in cash. As the factual prerequisite for breach of the repayment restrictions was absent, the penalty was deleted.

Interest awarded on enhanced compensation under Section 28 of the Land Acquisition Act, 1894 is treated as an accretion to the acquired land's value and forms part of enhanced compensation, unlike Section 34 interest, which compensates for delayed payment. The receipt consequently qualifies for exemption under Section 10(37) of the Income-tax Act, 1961 where its conditions are met, rather than taxation as income from other sources. Provisions taxing interest on receipt do not alter the character of Section 28 interest. A summary dismissal of a special leave petition does not establish binding law, and an assessment adopting the exemption view after inquiry is not erroneous and prejudicial to Revenue for revision purposes.

Functional comparability under the Transactional Net Margin Method requires alignment of functions and risk profile; a full-risk advisory and procurement consultant is unsuitable for benchmarking routine, low-risk corporate support services. Deduction for eligible units remains available where prior jurisdictional precedent governs profit allocation despite the absence of separate books. Bank guarantee fees are not commission or brokerage because the bank acts on its own account, without a principal-agent relationship; tax deduction at source and consequential disallowance therefore do not arise. Rule 8D may be applied only after recorded dissatisfaction with the assessee's claim. Rule 8D disallowance also cannot be added to book profit under minimum alternate tax provisions.

Section 32(1)(iia) permits the unclaimed balance of additional depreciation on new plant and machinery in the succeeding assessment year where the asset was put to use for less than 180 days in the year of acquisition. Where only part of the additional depreciation was allowed initially because of restricted use during that year, the remaining balance is available subsequently. This treatment follows binding jurisdictional precedent and is supported by an earlier determination on the same issue in the assessee's own matter.

Food-grain transactions conducted through an aartia did not establish bogus or accommodation purchase entries where the assessee advanced funds but neither took delivery nor paid or received the underlying purchase or sale consideration. The aartia independently purchased and sold goods on the assessee's behalf, while the assessee received only the net surplus disclosed in its return. On those facts, the addition for alleged accommodation purchase entries was deleted for both assessment years.

Cash deposits made during demonetisation and attributable to bullion sales recorded in audited books should not be separately added as income where the books show corresponding trading stock and bank deposits, no defects are identified, and the books are not rejected. As the sales have already been offered to tax, a separate addition of their deposited proceeds creates double addition. On these facts, the cash-deposit addition is unsustainable and requires deletion.

Completed or unabated assessment years under section 153A permit additions or appellate enhancement only when founded on incriminating material found during a search or requisition under sections 132 or 132A. Where no assessment proceeding was pending on the search date and the additions or enhancement lacked that material basis, they could not be sustained. The additions and enhancement for the completed assessment years were therefore deleted.

Penalty under Section 271(1)(c), when founded solely on an assessment framed under Section 143(3), cannot stand once that assessment is reversed following revision under Section 263. Removal of the foundational assessment eliminates the basis for the consequential penalty under the principle sublato fundamento cadit opus. The penalty was therefore unsustainable and deleted in favour of the assessee.

External development charges paid to HUDA attract tax deduction at source under Section 194C of the Income-tax Act. Binding jurisdictional precedent places these payments within Chapter XVII, so failure to deduct permits treatment of the payer as an assessee in default under Sections 201(1) and 201(1A), with consequential interest liability.

Deletion of stock addition is sustainable for assessment years sharing facts with an earlier year where the Assessing Officer's remand report accepts the assessee's case on merits. The earlier appellate finding stood unchallenged by the Revenue because the favourable remand report left it without a grievance. Applying the same factual position, deletion of the stock addition was confirmed for both assessment years.

Unexplained cash-credit addition for unsecured loans from farmers remained sustained because the loans' genuineness was not established before the appellate authority and no fresh material displaced that finding. A separate bank-reconciliation claim required factual verification before its tax treatment could be determined and was restored to the Assessing Officer for verification and fresh adjudication. The loan-credit addition therefore remained sustained, while the reconciliation claim awaited fresh determination.

Unexplained cash-credit additions require the taxpayer's initial evidentiary burden to be assessed through confirmations, financial records, banking evidence and statutory filings; non-service of third-party summons alone does not disprove documented transactions. Additions for unexplained money or expenditure require reliable material linking the taxpayer to actual unaccounted cash receipts or payments. Purchase disallowances require evidence beyond supplier non-compliance where invoices, stock records and sales support the purchases. Hundi-based additions apply only to transactions possessing hundi characteristics. For unabated search assessments, additions require incriminating material seized pursuant to the taxpayer's warrant; third-party material must be addressed through the statutory procedure for material belonging to another person.

Chapter VI-A deduction claims under Section 80P(2)(a)(i) made in returns filed in response to reassessment notices for years before AY 2018-19 are not barred solely because the returns were filed after the Section 139(1) due date; substantive eligibility and quantum remain subject to verification. From AY 2018-19, Section 80AC(ii) makes timely filing under Section 139(1) mandatory, and a belated return under Section 139(4) cannot cure non-compliance. Cash-deposit additions require cogent contrary material where an explanation based on the same business activity has been accepted in adjacent assessment years, applying the consistency principle.

Interest on fixed deposits placed with a co-operative bank by a co-operative credit society qualifies for deduction under Section 80P(2)(a)(i) where the deposits comprise funds generated through member-lending activity. The required "attributable to" connection is met because prudent placement of those funds has a proximate nexus with the society's credit business, allowing the interest to retain its business-income character. Dividend received from the co-operative bank also qualifies for the deduction, consistently with the treatment of dividend income earned by co-operative societies.

For reassessment initiated after the prescribed three-year period under the pre-1 April 2023 framework, approval for the order under section 148A(d) and notice under section 148 had to be obtained from the Principal Chief Commissioner or Chief Commissioner under section 151(ii). The extension provisions in section 149 could not alter that sanctioning requirement without an express enabling provision. The Finance Act 2023 proviso to section 151 operated prospectively and could not cure prior approval by a Principal Commissioner. Sanction by an incompetent authority rendered the resulting reassessment proceedings unsustainable.

For share-premium taxation, CCPS fall within the valuation framework for unquoted securities other than equity shares. A valuation prepared under the prescribed method cannot be displaced by applying the separate method for unquoted equity shares. DCF valuation must be assessed using facts and financial data available on the valuation date; subsequent losses do not by themselves invalidate it. Standard disclaimers in a valuation report are not independently sufficient to reject the valuation. Issuance of CCPS by a wholly owned subsidiary to its holding company does not, without specific evidence, establish unaccounted income or artificial inflation of share value.

Delivery of a motor vehicle with its original documents can constitute a completed sale where possession and property pass, even if ownership transfer is not registered under motor-vehicle rules. Under the Sale of Goods Act, delivery and payment are concurrent conditions; a retained duplicate key may indicate only a seller's lien, while non-payment engages unpaid-seller remedies. A transaction not made on approval or sale-or-return is not governed by those conditional-sale rules. A delayed complaint after seizure may not justify writ interference with an assessment.

Section 153C jurisdiction requires seized incriminating material concerning the other person, recorded satisfaction identifying its nexus to each relevant assessment year, and compliance with the statutory block period. For a person other than the searched person, receipt of seized material by the jurisdictional Assessing Officer is the deemed search date. Material received in March 2021 placed Assessment Year 2021-22 at the start of the ten-year block, extending only to Assessment Year 2012-13; notices for Assessment Years 2008-09 to 2011-12 were therefore invalid. The block period does not permit reopening years without year-specific material and corresponding satisfaction.

For a search conducted in Financial Year 2023-24, the extended ten-year assessment block is computed under Explanation 1 to section 153A from the end of the assessment year relevant to the previous year of search. Assessment Year 2024-25 is therefore the first year of that block and Assessment Year 2015-16 its tenth year. Assessment Year 2014-15 falls outside the extended period. The distinct six-year and ten-year computational regimes under sections 149, 152(3), 153A and 153C consequently render reassessment notice for Assessment Year 2014-15 barred by limitation.

Payments for rights limited to live telecast of a sports series, without rights to record, preserve, or re-telecast the feed after the relevant events, do not constitute royalty under Section 9(1)(vi) of the Income-tax Act, 1961. Royalty requires an enduring benefit or exploitation right. Restricted live-feed rights that expire with the events do not confer such enduring rights; therefore, consideration paid to the overseas rights holder is not chargeable to tax as royalty.