For non-searched persons, the deemed date of search under the first proviso to Section 153C(1) governs computation of both the six-year and extended ten-year assessment blocks. Binding jurisdictional precedent treats the relevant date as the receipt or handover of seized books, documents or assets to the Assessing Officer having jurisdiction over that person, rather than the date of the original search. Where the satisfaction note and notice arise in financial year 2021-22, the permissible ten-year block runs from assessment year 2013-14 through assessment year 2022-23. Assessment year 2012-13 consequently falls outside that block.

Advance pricing agreement coverage for earlier years does not bind benchmarking for an uncovered year, but remains persuasive where the transaction, methodology and functional, asset and risk profile continue; departure requires material differences. Comparable companies accepted in the preceding year should not be removed solely under a turnover filter absent a finding that turnover materially affects operating margins, subject to other comparability requirements. A comparable exceeding the adopted related-party transaction threshold must be excluded because segmenting related-party income and expenditure does not eliminate the influence of controlled transactions on overall profitability. Where revised comparables place the tested party's operating margin within the arm's-length percentile range, no transfer-pricing adjustment is warranted.

Foreign companies qualify as eligible assessees under the statutory dispute-resolution procedure. Where a prejudicial variation is proposed, the Assessing Officer must first issue a draft assessment order, allowing the foreign company to accept the variation or object before the Dispute Resolution Panel. A final assessment may be completed only after following the prescribed process. Issuing a final assessment order without a prior draft order breaches a mandatory requirement and invalidates the assessment.

Rebate under Section 87A is available against tax payable on short-term capital gains taxable at special rates under Section 111A where the taxpayer opts for the Section 115BAC(1A) regime. Section 87A applies to tax liability on total income without distinguishing normal-rate income from special-rate capital gains. Neither Section 111A nor Section 115BAC(1A) expressly excludes such gains from the rebate, and the concessional tax regime does not impliedly limit the independent rebate entitlement. Tribunal decisions supporting this interpretation were not displaced by contrary High Court or Supreme Court authority.

Section 87A permits a rebate from income tax on total income without excluding tax on short-term capital gains taxed at special rates under Section 111A for the relevant period. Section 111A contains no corresponding restriction. By contrast, the express exclusion for long-term capital gains under Section 112A(6) shows that any restriction on special-rate income requires specific enactment. Section 115BAC(1A) does not limit the independently available rebate, and a proposed prospective amendment cannot restrict the unamended provision. Rebate is therefore available against tax payable on such short-term capital gains.

Section 69C unexplained-expenditure additions require the Revenue to displace reliable substantiating evidence. Labour and manpower expenses supported by invoices, ledger accounts, bank payments after tax deduction, audited accounts and GST records cannot be treated as unexplained merely because the service provider failed to answer a third-party notice, particularly where no further enquiry contradicts the evidence. Purchase entries included in closing work-in-progress, followed by return of goods, no payment and reversal of GST input credit, do not create unexplained expenditure where they produce no effective deduction or taxable-income impact. Documented transactions and neutralised purchase entries therefore do not justify an unexplained-expenditure addition.

Income-tax additions for alleged unrecorded coal purchases require independent evidence linking third-party search material to the taxpayer. Where books are not rejected and no abnormality in production, consumption, input-output ratios or recorded sales is established, a net-profit estimate based on suspected outside-the-books trading is speculative and cannot stand. Likewise, alleged under-invoicing of mill-scale sales cannot be established solely through a retracted statement and CCTV footage when the cash is recorded and supported by available cash balances. Additions based on uncorroborated material, retracted statements and presumptive estimations are deleted.

Reasonable cause may preclude penalties for failures to deduct or collect tax where a bona fide belief is objectively supportable. Payment of rent to a Government-owned company may support a genuine understanding that tax deduction is not required, particularly where the recipient has the character of a State instrumentality. Construction scrap generated through labour and materials may be regarded as outside tax-collection requirements where it does not arise from a manufacturing process. On these principles, bona fide beliefs concerning both obligations can constitute reasonable cause and prevent penalty.

Foreign tax credit claimed under Sections 90/90A is not defeated solely because Form No. 67 was filed after the prescribed timeline. Rule 128(9), which requires furnishing the form, operates as a directory procedural requirement where the credit was claimed in the return and the delay does not undermine the substantive entitlement. The credit remains available subject to the Assessing Officer verifying the relevant facts and supporting documents after providing an opportunity of hearing.

Section 11(1)(a) permits charitable trusts to retain the statutory 15% accumulation independently of the specified accumulation regime under section 11(2). Accumulation beyond that limit remains available where Form No. 10 is furnished by the valid extended return-filing deadline under Rule 17 read with section 139(1). Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late when the audit report was available before return processing and the substantive exemption conditions were satisfied. Procedural delay in prescribed filings does not defeat the exemption where the relevant form is timely under an extended deadline or the audit report is available before proceedings conclude.

Repeated cash deposits followed by similar self-withdrawals and redeposits may establish circulation of the same funds, requiring unexplained-money additions to be computed on the net peak credit rather than gross deposits. Opening cash balance, verified net agricultural receipts, and other disclosed income constitute explained sources and must be credited when determining any unexplained peak. Only the residual unexplained amount remains liable to addition. The amended tax-rate provision for unexplained income, effective from 1 April 2017, applies to Assessment Year 2017-18.

Section 194C(6) TDS exemption for small goods-carriage contractors requires a declaration and PAN, with sufficient particulars to establish eligibility where inquiries reveal discrepancies. Freight-payment and vehicle-registration details may be material in that assessment, but non-verification by the deductor or departure from the Circular No. 19/2015 format alone does not defeat the exemption. Identified declaration defects must be put to the deductor for explanation or cure. Under the first proviso to Section 201(1), physical Form 26A certificates must be examined to verify whether payees reported the freight income and discharged the related tax. Default status and consequential interest require determination after applying these standards.

Interest on bank overdraft funds advanced for a proposed business land acquisition may retain revenue character where the acquisition is abandoned and the advance is refunded before any asset comes into existence. The deductibility of such expenditure is at least legally supportable and debatable; disallowance in quantum assessment alone does not establish concealment of income or furnishing inaccurate particulars. Accordingly, a revenue-expenditure claim of this nature, when not outrightly unsustainable, does not justify concealment penalty under Section 271(1)(c).

Closing stock must be valued at cost or market value, whichever is lower. A stated net realisable value requires supporting material showing its basis; where the taxpayer's rate is unsupported and the assessing officer's market-realisation rate is below cost, the issue concerns the correct realisable-value rate rather than a change in valuation method. Consistent use of a net realisable value method does not protect an unsubstantiated valuation rate. Concurrent factual findings on valuation disclosed no substantial question of law, and the addition for undervaluation of closing stock was sustained.

Purchase additions and wage disallowances cannot rest on suspicion or unsupported presumptions when ledger accounts, invoices, supplier details, bank statements and crossed-cheque payments remain unrebutted. Supplier confirmations alone are not indispensable where no inquiry disproves the purchase records, banking entries or underlying transactions. Likewise, wage expenditure cannot be disallowed merely on an assumption that registers were prepared later or wages were inflated; contrary material and reasons are required. The purchase addition and wage disallowance were therefore treated as unsustainable, restoring the corresponding deletions.

Revisionary jurisdiction under Section 263 cannot be invoked merely because the revisional authority considers enquiries into seized material inadequate after the Assessing Officer has conducted them and adopted a plausible view. Detailed notices, confrontation with seized documents and statements, and consideration of the assessee's explanations demonstrate that the assessment was not made without enquiry. Section 263 applies where lack of enquiry makes an assessment both erroneous and prejudicial to Revenue; it does not permit substitution of the revisional authority's view for a considered assessment decision. The proposed revision was therefore unsustainable.

Reassessment initiated in the name of a deceased assessee does not comply with the statutory mechanism requiring assessment through the legal representative and is invalid. Sale proceeds from land deposited in a bank account may remain an asset for the extended reassessment period because the inclusive definition covers immovable property and bank deposits, where alleged escaped income crosses the prescribed threshold. However, a co-owner's valuation report alone cannot support reassessment: the Assessing Officer must independently examine the assessee's property, undertake appropriate valuation inquiry, consider tangible material, and form a belief that income escaped assessment. Proceedings founded solely on an unverified co-owner valuation are impermissible.

Reassessment notices alleging fictitious or accommodation transactions must disclose sufficient material particulars and the relied-upon incriminating material that prima facie links the assessee to the alleged income escapement. Transaction screenshots identifying values and entities, without the underlying dissemination reports, do not provide an effective opportunity to respond under the statutory pre-notice procedure. The Assessing Officer must meaningfully consider the assessee's documentary explanation and identify material supporting the alleged role in the transactions. Disclosure of relied-upon reports only during writ proceedings cannot cure the initial denial of a meaningful statutory opportunity. Reassessment proceedings initiated without such disclosure are invalid.

Agreements concerning jointly held ancestral land did not establish a transfer of the assessee's capital asset for long-term capital-gains purposes. The land covered by the joint development arrangement was allotted to other family members under the subsequent agreement and final partition decree, while the assessee retained land allotted to his own share. The factual finding of no transfer was supported by the record and was not perverse; deletion of the long-term capital-gains additions was therefore sustained.

Section 179(1) imposes personal liability for unrecovered tax dues only on directors of a private company where non-recovery is attributable to their gross neglect, misfeasance or breach of duty. An incorporated unlisted public company does not become a private company merely because shareholding is concentrated or its shares were not publicly offered. Corporate veil principles require exceptional circumstances, such as use of the company to siphon income or create undisclosed assets, before extending liability beyond the statutory scope. Authorities must consider a director's explanation, record a reasoned causal link between the director's conduct and non-recovery, and disclose adverse material to preserve natural justice.