Reassessment initiated on departmental information flagged through the Insight Portal remains valid where the Assessing Officer independently confronts the taxpayer with the information, considers the response, passes an order under section 148A(d), and then issues notice under section 148. Such information may provide a starting point for enquiry without constituting borrowed satisfaction. However, sale proceeds from shares cannot be treated as unexplained accommodation entries merely on investigation allegations or suspicion where broker transactions, demat records, contract notes and banking channels remain undisputed, and no independent corroboration, cash trail, or link to an entry provider is established. The reassessment survived, but the share-sale addition was deleted.

Uncorroborated electronic records cannot alone support additions for unexplained investments, expenditure, interest, sales or debtor balances unless independent evidence establishes their nexus with the assessee and the recorded transactions. Excel worksheets, payment sheets and electronic debtor data containing inconsistencies, without supplier or debtor verification, books, invoices, banking records or other supporting material, failed this standard; the related additions were deleted. WeChat diary figures were accepted only to the extent actually recorded, with gross profit estimated thereon, because no evidence justified applying a multiplier. Cash-rent expenditure was disallowed for want of receipts, ledger entries, landlord confirmation or payment proof, and unexplained stock investment was sustained because the stock difference remained unreconciled.

Cash deposits fully disclosed through a revised computation during assessment, with tax paid and the computation accepted, may constitute under-reporting rather than misreporting where the assessment does not identify any statutory ingredient of misreporting. Assessment of the deposits as income from other sources does not itself establish misreporting. On that classification, immunity from penalty for under-reporting is available, and penalty imposed for misreporting is unjustified. The appeal was allowed.

Section 54F eligibility depends on residential houses owned by the assessee personally. A residential property owned by a company remains the company's asset and is not treated as owned by its director. Where the assessee also jointly owns a property with a spouse, counting that property still leaves only one residential house other than the property in which the qualifying investment is made. The disqualifying condition for ownership of more than one such house therefore does not apply, and the section 54F deduction remains available.

Revaluation surplus credited to a retiring partner following revaluation of partnership land does not constitute the partner's share in the firm's total income and is not exempt under section 10(2A). For the relevant assessment year, distribution of the enhanced value of partnership assets attracted section 45(4), under which the resulting capital gains were taxable in the firm's hands rather than in the retiring partner's hands. The post-1 April 2021 substituted provisions did not apply. Accordingly, the addition of the revaluation surplus in the retiring partner's assessment was deleted, although the exemption claim was rejected.

Undisclosed business receipts following rejection of books require profit estimation at a fair rate based on disclosed margins, past results and comparable data; the estimated rate was reduced to 12%. Impounded-document presumptions are rebuttable, and entries cannot be selectively used while corresponding outgoings are ignored; unsupported additions were deleted. Standard off-the-shelf software acquired for internal use without copyright transfer is a goods purchase, so no tax deduction at source applies. Stock statements given to banks, uncorroborated loose-sheet notings and estimated election-expense papers cannot alone establish unexplained investment or expenditure. Rejected books cannot support a separate cash-credit addition after bu.....

Section 153C distinguishes a searched person from an other person by the name in the search warrant and the statutory satisfaction recorded; ownership or occupation of searched premises alone does not confer searched-person status. For completed or unabated assessment years, additions must rest on incriminating material found during search that pertains to each relevant year. Material relating to a later year and uncorroborated general admissions cannot support additions for earlier years. In liquor-business profit estimation, commercially plausible indirect expenses cannot be rejected outright solely because complete vouchers are unavailable, and separate addition of expenses already excluded in computing net profit results in impermissible double addition.

Rule 17A(2) distinguishes institutions created or established under a written instrument from those created otherwise than under an instrument. For the latter, absence of a formal trust deed or memorandum of association cannot alone justify rejecting renewal of charitable registration. The registration authority must assess alternative documentary material, including public-trust registration, the underlying application, prior income-tax registrations and other evidence, to establish the institution's creation and continuing existence. Where no adverse finding concerns charitable or religious objects or the genuineness of activities, rejecting renewal solely for want of a separate formal instrument is unjustified. Registration renewal under section 12AB should be granted in accordance with law.

Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.

Section 41(1) applies only where expenditure or a trading liability was previously allowed as a deduction and the taxpayer subsequently obtains a benefit through remission or cessation. Unpaid interest earlier disallowed under section 43B did not satisfy that condition. Continued balance-sheet recognition, with no write-back, waiver, settlement or discharge, also did not establish cessation; a lender's discounted assignment to an asset reconstruction company did not extinguish the debt. The addition was deleted. Depreciation remained available for a mortgaged building in an existing asset block because mortgage does not transfer ownership and no sale, discard, business unavailability or permanent closure was shown; depreciation was allowed.

Interest and dividend earned by a co-operative society from deposits or investments with a co-operative bank qualify for deduction under section 80P(2)(d). A co-operative bank registered under co-operative societies law retains its character as a co-operative society for this purpose. Section 80P(4) excludes a co-operative bank from claiming deduction on its own income, but does not bar another co-operative society from claiming deduction on income derived from investments with that bank. The deduction applies to interest and dividends from the co-operative bank; expense-allocation grounds were not pressed.

Subsisting registration under section 12AB remains legally effective until lawfully withdrawn or cancelled, even if the trust selected an incorrect sub-clause in an earlier registration application. Renewal falls under section 12A(1)(ac)(ii) where an existing section 12AB registration is due to expire. Absence of registration under the earlier section 12A/12AA regime does not justify rejection where no adverse finding concerns the objects, genuineness of activities, or registration conditions. Renewal rejection on that basis was set aside and registration was directed for the applicable period.

Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.

Section 110(5) permits provisional attachment of bank accounts only upon strict compliance with substantive and procedural conditions, including the Commissioner's approval. Provisional attachment orders issued without that approval, consequential extensions, and debit-freeze directions unsupported by written reasons or approval are invalid. Written attachment orders made after approval, during proceedings against the concerned exporters, and recording the proper officer's reasons satisfy the statutory requirements and remain effective. Extension of a provisional attachment requires a pre-decisional hearing and recorded reasons; an extension made without notice, hearing, or reasons cannot be cured by a later hearing and must be set aside, subject to fresh action in accordance with law.

Section 110A of the Customs Act makes all seized goods eligible for provisional release, subject to the competent authority's discretionary assessment of entitlement. Goods notified under Section 123 cannot be categorically excluded from provisional release through CBIC Circular No. 35/2017-Cus. An executive circular cannot add exclusions absent from, or override, the parent statute. The Tribunal's direction for provisional release was therefore sustained, and the appeal challenging that direction was dismissed.

Export Obligation Discharge Certificate issuance after submission of required particulars establishes fulfilment of EPCG authorisation conditions, including the export obligation and actual-user requirement for concessional-duty car imports. Where non-production of the certificate in earlier proceedings was beyond the importer's control, its subsequent grant removes the legal basis for alleging non-compliance. Consequently, customs duty demand, confiscation of the imported car, redemption fine and penalties for the alleged breach of EPCG conditions cannot be sustained.

Statutory presumption for notified gold arises only when seizure rests on reasonable belief, supported by objective material, that the particular gold was smuggled. Purity, lack of documents at interception and private carriage do not establish foreign origin. Domestic acquisition may be established through contemporaneous invoices, supplier confirmation and banking records; confiscation for breach of an import exemption condition requires identification of that breached condition. Statements recorded under customs powers remain admissible, but retracted statements require scrutiny of voluntariness, reliability and independent corroboration. Where such statements and a panchanama are challenged, denial of cross-examination of their makers m.....

Annulment of a securities trade ends the transaction and makes subsequent physical delivery of the shares purposeless where the shares have been returned to the selling member. The purchaser is entitled to recover the purchase consideration with interest from the Exchange, rather than pursue trading-loss damages. The selling member is not a necessary party because the settlement mechanism creates no direct buyer-seller contract requiring relief against that member after annulment; arbitration and closing-out remedies are therefore inapplicable. An indemnity limited to dispute-resolution references does not grant the Exchange general immunity, and Clearing House non-liability provisions concerning title or validity of securities do not bar refund liability arising from annulment.

Corporate capacity under the memorandum of association did not extend to investment of preferential-issue proceeds in virtual digital assets merely because the activity had been added to the ancillary objects clause. Schedule I distinguishes a company's stated objects from matters necessary for furtherance of those objects; the first amendment addressed only the latter, while a later amendment added virtual digital asset business to the main objects clause. Until that main-objects amendment, fund raising and investment for that business were ultra vires. The listing application therefore could not be considered on the first amendment alone, and its return was upheld.

Property of equivalent value may be provisionally attached under the anti-money-laundering framework when directly or indirectly derived proceeds of crime are unavailable, siphoned off or have vanished. Such attachment is not restricted to assets acquired after the scheduled offence, and a disclosed legitimate source of acquisition does not prevent attachment where the asset is targeted as equivalent value rather than as proceeds of crime. For jointly owned property, attachment must remain limited to the value of proceeds attributed to the accused and cannot extend to a co-owner's independent share. The provisional attachment was sustained on that limited equivalent-value basis, and the appeal was dismissed.