Reassessment under Section 147 remained valid because investigation material from a search established a nexus between accommodation-entry operators and the loan creditors. However, additions for alleged bogus loans were deleted where confirmations, income-tax returns and banking records of the creditors were produced, the loans were fully repaid in the following financial year, and no corresponding addition was made for that year. Repayment through banking channels negated the allegation that the loans were accommodation entries; consequently, the related estimated unexplained expenditure addition had no basis.

Bona fide pursuit of settlement under the Vivad Se Vishwas Scheme, followed by rejection of the settlement form, non-resident status, and ensuing circumstances constituted sufficient cause to condone the filing delay. Cash deposits in a jointly held NRO account were not taxable as the assessee's unexplained investment where passport and bank records supported accumulated foreign earnings, remittances, and withdrawals from that account, and four family members held the account jointly. The cash-deposit addition was therefore deleted.

Section 69A requires a satisfactory explanation of the nature and source of jewellery found in a taxpayer's possession. Valuation reports for the taxpayer and family members may support a claim that jewellery is old and derived from ancestral inheritance and gifts accumulated over time. CBDT Instruction No. 1916 operates as a guiding measure in assessing explained family jewellery, with family status, customary practices and relevant circumstances considered. Jewellery within the family-based benchmark, including marginal excess, was treated as reasonably explained rather than taxable unexplained income.

Section 50C does not apply where consideration is received for relinquishing an unregistered contractual right to seek specific performance of a land-sale agreement. Such a right is a capital asset, and its relinquishment constitutes a transfer, but it does not amount to transfer of land, building, or both. The deeming fiction in Section 50C must be construed strictly and cannot extend to a contractual right concerning land. This differs from a registered leasehold interest, which creates an interest in rem with possession and enjoyment. Long-term capital gains cannot be recomputed under Section 50C on this basis, and the consequential addition is deleted.

Approval for reassessment under section 151 requires proper and independent application of mind to the alleged escaped income. Where sanction was obtained on a materially higher alleged amount than the amount subsequently adopted in the order under section 148A(d), the discrepancy indicates uncertainty in the basis for reopening. Such a material variation renders the sanction legally unsustainable, invalidates the approval, and prevents reassessment initiation from being sustained.

Reassessment initiated on information about interest income cannot be sustained where no addition is made on that recorded ground and the resulting addition concerns alleged unexplained bank credits. An addition on a different issue, without any addition for the reason recorded to reopen the assessment, renders the reassessment and consequential addition unsustainable.

Search-triggered information suggesting escaped income requires use of the special assessment mechanism under section 148 rather than continuation of a regular assessment under section 143(3). The special search-related procedure prevails over the general assessment framework because it preserves statutory safeguards applicable after a search under section 132. Accordingly, a regular assessment completed under section 143(3) after the search was treated as legally unsustainable and quashed.

Section 69A applies where money or valuable articles owned by an assessee are not recorded in its books. A recorded subscription to secured redeemable non-convertible debentures, reflected as a liability and supported by subscriber identification, banking records, audited financial statements, corporate approvals, listing permissions and trust documents, could not be treated as unexplained money without evidence that it represented the assessee's undisclosed funds. Investigation material concerning alleged accommodation entries lacked a direct nexus with the relevant assessment year. The human-probabilities test could not replace material evidence disproving the documented transaction, rendering the addition unsustainable.

Section 68 applies only to sums credited in books maintained by the taxpayer; a bank passbook or account statement is not such books where no books are kept. Accordingly, the cash-deposit addition was removed. Claims for indexed conversion charges and other improvement costs require verification of evidence, timing, nature and nexus to the transferred land before capital-gains deduction. Claims concerning capital gains on property allegedly owned by a former spouse and foreign rental income must be examined when raised in DRP proceedings, even if absent from draft-order variations. A fresh Section 54F exemption claim lacking verified facts on investment, ownership and statutory conditions cannot be entertained at the Tribunal stage.

Penalty proceedings under Section 271D for contravention of Section 269SS require the Assessing Officer to record satisfaction concerning the alleged breach during assessment proceedings. Where an assessment completed under Section 144 contains neither such satisfaction nor initiation of penalty proceedings, the jurisdictional basis for the penalty is absent. The resulting penalty proceedings are invalid, requiring deletion of the penalty for want of valid assumption of jurisdiction.

Business-income estimation for a vegetable-market commission agency must reflect activity-specific expenses, including loading, unloading, salaries and administration, after receipts are accepted as turnover. Net-profit results from the immediately succeeding assessment year and comparable taxpayers may guide the rate but are not mechanically determinative. Incomplete records and substantial transaction volume support a reasonable estimated profit. Applying these factors, income is estimated at 2% of total receipts rather than 4%, with consequential recomputation.

Section 14A disallowance for Assessment Year 2018-19 does not arise where no exempt income was earned. The Finance Act 2022 Explanation extending the provision to years without exempt income applies prospectively from Assessment Year 2022-23. For an outstanding sundry creditor liability, production of books, ledger extracts, payment particulars and contemporaneous supporting records discharges the taxpayer's primary burden. A creditor's non-response to a notice seeking information, without evidence that the transaction was fictitious or the liability nongenuine, does not justify adding the entire balance; restricting the addition where verification remains incomplete is treated as reasonable.

Penalty for concealment or furnishing inaccurate particulars does not arise merely because a statutory-tax liability is disallowed under Section 43B where the liability was recorded through the balance sheet, not claimed as profit-and-loss expenditure, and fully disclosed in the tax-audit report. A plausible legal claim and complete disclosure distinguish a quantum disallowance from penal conduct. Similarly, foreign dividend income disclosed in Schedule SI at the applicable special rate, but omitted from the summary computation through a reporting mismatch, does not support penalty where rectification was voluntarily sought before revisionary proceedings and there was no deliberate suppression or tax evasion.

The beneficial tolerance provision in the third proviso to Section 50C is treated as retrospectively applicable, requiring adoption of the declared sale consideration and preventing an addition where the DVO valuation exceeds it by no more than 10%. Bona fide pursuit of rectification proceedings before the appellate authority, followed by prompt filing after rejection, constitutes reasonable cause for a 60-day filing delay.

Royalty payments inseparably linked to manufacturing and benchmarked under an aggregated TNMM approach should not be separately tested or recast as a cost contribution arrangement without a material change in facts; the related transfer-pricing adjustment is removed. Engineering and design comparables require functional similarity and reliable segmental data; a diversified entity lacking reliable segmental information and affected by an extraordinary acquisition should be excluded, requiring recomputation of the margin. Expenditure attributable to exempt income may be disallowed under Section 14A and amended Rule 8D once the Assessing Officer records dissatisfaction with the taxpayer's claim; the disallowance is sustained where personnel costs were omitted.

Reassessment beyond three years requires recorded reasons and approval linking escaped income exceeding the threshold to an identified asset, qualifying expenditure, event or book entry under section 149(1)(b); unaccounted receipts or payments alone do not meet that jurisdictional condition. For a pre-search assessment year, an assessment under section 143(3) without recourse to sections 147 and 148 lacks the prescribed statutory basis. Electronic material, including WhatsApp chats and cash books, must be authenticated and corroborated through source extraction, chain of custody, transaction context and year-specific evidence. Retracted statements, unexplained figures and unreconciled cash-book entries cannot, without independent corroboration, establish unaccounted sales or support net-profit estimation.

Payment under the Direct Tax Vivad se Vishwas Scheme satisfies section 5(2) where a revised Form-3 imposes a deadline that had expired before its issue, but the declarant pays the determined amount within fifteen days of receiving the certificate and submits Form-4. A deadline incapable of literal compliance cannot support a demand or interest for non-compliance. Upon valid payment and intimation, the designated authority must record payment and issue Form-5.

Reassessment requires income to have escaped assessment. Where a company validly adopted a 15-month first financial year under the Companies Act, 2013, and disclosed the entire income for that period in its assessment-year return, including the income targeted in reassessment proceedings, no income remained undisclosed or escaped. Reassessment is therefore impermissible where the proposed addition concerns income already returned for the valid first financial year.

Limitation for a notice under Section 153C depended on the six-year look-back period applicable where alleged escaped income was below Rs. 50 lakh. Because the satisfaction note was recorded in assessment year 2023-24, the period reached back only to assessment year 2017-18. Assessment year 2016-17 therefore fell outside the prescribed period, rendering the notice time-barred in favour of the assessee.

Section 153A read with Section 153C permits a ten-year assessment period only where escaped income exceeds the prescribed threshold. Where the satisfaction note was recorded in assessment year 2024-25, the backward computation reached only assessment year 2015-16. Notice issued for assessment year 2010-11 was therefore beyond limitation, time-barred and invalid.