Assessment under section 143(3) must be made in the name of an assessee that exists when the order is passed. Where a partnership firm converts into a private limited company and the Assessing Officer is informed before assessment, the firm ceases to be an assessable entity. An assessment subsequently issued in the former firm's name is void because settled principles prohibit assessment of a non-existent entity. The resulting assessment order is liable to be quashed.

Service-tax turnover and income-tax revenue may differ in real-estate projects because service tax applied to advances received, while income under the mercantile system and Percentage of Completion Method is recognised at the relevant stage of project completion. Customer advances remain liabilities until then. Where audited books, financial statements and project-wise workings support recognised revenue, no accounting discrepancy is shown and the books are not rejected, the mismatch is a timing and accounting-basis difference. It cannot be treated as unaccounted turnover or taxable income, supporting deletion of the addition.

Section 271AAB requires undisclosed income to be represented by money, bullion, jewellery, another valuable article or thing, or an entry, document or transaction found during a search. A stock shortage identified by comparing physical inventory with book stock is an absence, not search material. Where alleged unrecorded sales are inferred solely from that shortage and gross profit is estimated without evidence of outside-the-books sales or false expense entries, the estimated profit does not satisfy the statutory definition of undisclosed income. Penalty proceedings remain independent of assessment proceedings, and acceptance of an addition is not conclusive. Strict construction places the burden on the Revenue to establish all statutory conditions; penalty is therefore unsustainable.

Registration eligibility under section 12A(1)(ac)(vi), reflected in section code 4A, depends on whether income was actually excluded from total income under sections 11, 12 or specified section 10(23C) provisions. Filing Form ITR-7 alone is not conclusive evidence that those exemptions were claimed or availed. An application should not be treated as non-maintainable solely because that return form was used; the returns, schedules, computations, and processing or assessment records require examination.

Section 69 requires an investment addition to rest on an unexplained or unsatisfactorily explained source. Verified bank payments and housing-loan financing may establish the source of payments for jointly acquired property, and another co-owner's contribution cannot be treated as one purchaser's unexplained investment. For stamp-duty valuation purposes, documented additional consideration must be included in the actual aggregate consideration before determining any difference. In a joint purchase, only the amount attributable to the relevant co-owner may be assessed; the entire difference cannot be brought to tax in one co-purchaser's hands, particularly where that share falls below the statutory threshold.

Binding CBDT Instruction No. 1/2011 allocated assessment jurisdiction over a non-corporate taxpayer reporting income above the prescribed threshold to an Assistant or Deputy Commissioner, not an Income-tax Officer. Reassessment initiated, noticed and completed by an Income-tax Officer despite that allocation was treated as void for inherent lack of pecuniary jurisdiction. The unsecured-loan addition remained deleted because remand verification disclosed no adverse finding and Revenue produced no contrary evidence, legal error or factual infirmity; characterising the remand report as a draft did not displace the appellate findings.

Additional evidence consisting of a Departmental Valuation Officer's report on the fair market value of jointly purchased property is relevant to an addition for the difference between purchase consideration and stamp duty value under section 56(2)(x). Where the report directly bears on that valuation difference and requires verification at the assessment stage, the evidence may be admitted and the addition remitted to the Assessing Officer for verification and fresh adjudication after a reasonable hearing opportunity. All contentions on the merits remain open.

Reassessment initiated more than three years after the end of the relevant assessment year requires approval from the specifically designated higher authority under the applicable sanction provision. Approval by the Principal Commissioner did not satisfy that mandatory jurisdictional requirement. Treating an earlier notice under the former reassessment regime as deemed proceedings under the new procedure did not remove the requirement of competent approval for the consequential reassessment notice. The reassessment notice was therefore invalid, and the consequential reassessment, assessment and cash-credit addition were set aside.

Condonation of delay may be supported by COVID-19 disruption and the overseas location of key decision-makers where the explanation shows no mala fides. Transfer-pricing comparability requires reliable relevant-year financial and functional information, material functional similarity, and satisfaction of applied quantitative filters. Companies without verifiable public data, performing highly technical infrastructure-project services involving brand intangibles, carrying out government-driven diversified activities, or failing the employee-cost filter are excluded from the comparable set. The arm's length price determination excludes the four challenged comparables.

Section 68 does not permit an admitted advance received in financial year 2006-07 to be assessed as an unexplained cash credit in assessment year 2016-17. A subsequent land-sale transaction allegedly structured to obtain a capital-loss set-off may indicate tax avoidance, but cannot alter the year in which the advance was received or became taxable. Any alleged avoidance must be addressed through other applicable statutory measures rather than by treating the historic advance as a fresh unexplained cash credit.

An approved insolvency resolution plan that expressly bars tax claims for a pre-effective-date period binds revenue authorities, extinguishing unpreserved claims and precluding reassessment or revision for that period. The Insolvency and Bankruptcy Code's moratorium and overriding effect support that result. Separately, reassessment requires the prescribed preliminary inquiry, independent application of mind, disclosure of third-party material to permit a meaningful response, and compliance with limitation. Initiation founded only on external reports, without inquiry or disclosure, and beyond limitation is without jurisdiction. These requirements prevent reassessment claims that conflict with binding resolution-plan terms.

Acceptance of an alternative concession before the Tribunal barred the assessee from challenging the resulting disallowance of agricultural loss relating to saplings. Where the Tribunal had acted on the assessee's own alternative submission, the assessee could not maintain an appeal against that part of the order. The High Court therefore declined the proposed questions and dismissed the appeals.

Section 14A disallowance computed under Rule 8D for expenditure relating to exempt income is not a permitted adjustment to book profit for minimum alternate tax under Section 115JB. Binding jurisdictional decisions establish that the statutory computation disallowance cannot be added back while determining book profit, and the Revenue accepted that the issue was covered by this settled position. The question was therefore resolved in favour of the assessee.

Service of statutory reassessment communications through a secondary email address and at a former residential address did not afford the assessee an effective opportunity to respond to the notice under section 148A(b). As those modes of service were undisputed, sufficient cause existed to permit a response while leaving the merits for determination by the assessing authority. The reassessment and consequential proceedings were set aside, and the assessee was permitted to submit a response to the notice.

Export-profit deduction is computed under its own statutory formula, without first reducing deductions available for specified industrial or infrastructure profits. Restrictions against duplicate relief operate when deductions are actually allowed, preventing repeated deduction of the same eligible profits rather than changing export-deduction computation. Actual cost included in a block's written-down value cannot be revised for subsequent sales-tax or interest liabilities merely by characterising them as actual cost. Any adjustment requires an identified statutory mechanism and findings on the separate nature, crystallisation, relevant assets and affected block; the permissible treatment of each component must be determined separately.

Tax deduction at source on transferable development rights issued to a developer under a slum rehabilitation scheme, and on such rights issued as compensation for land acquired for public purposes, remained in issue. The High Court issued rule and stayed the challenged orders, demand notice and consequential proceedings pending final hearing. The petition was directed to be heard with a connected petition, leaving the tax-deduction question undecided at the interim stage.

Reassessment requires information that objectively suggests income has escaped assessment; a PAN-based attribution mismatch does not meet that threshold where the transferred business's income was disclosed and taxed by the demerged entity. Section 148A requires application of mind to supporting material and connected records, rather than reassessment merely for verification or a roving inquiry. The extended reassessment period applies only where books, documents, or evidence reveal previously undisclosed income meeting the statutory threshold. Recorded and taxed transactions requiring correlation are not undisclosed income, so they cannot support extended limitation after the ordinary period has expired.

Reassessment under Sections 147, 148 and 148A requires information indicating income has escaped assessment, with a live link and rational nexus to that conclusion. A Section 148A show-cause notice and the subsequent determination must consider the material on record and the assessee's reply. A verification report produced under Section 131(1A) cannot support adverse inferences extending beyond its limited inquiry without independent verification. Where audited accounts, bank records, utilisation details and vouchers are not addressed, and scrutiny is sought merely for further examination, the process is a roving inquiry. The jurisdictional threshold fails, making the determination and reassessment notice unsustainable.

Section 170A(2)(b) requires a modified return filed during pending assessment proceedings following a business reorganisation to be considered within those existing proceedings. A draft assessment order does not end the assessment because the DRP process continues until a final appealable order is passed. Section 170A(3) does not create a separate assessment cycle or allow general assessment provisions to override this specific mechanism. Where the modified return has been considered in the pending assessment and a final order issued, a fresh scrutiny notice, consequential transfer-pricing reference, and parallel proceedings lack statutory basis and suffer from a jurisdictional defect.

Spare-replacement activities conducted without ownership of the parts, control over resale prices, or customer selection are characterised as service-provider functions for transfer-pricing purposes. The functional, assets and risks profile supports benchmarking under the Transactional Net Margin Method where the entity merely holds and delivers replacement parts to customers of its associated enterprise under that enterprise's directions. The Resale Price Method is not appropriate for such custodial service activity, as the entity does not undertake trading functions or assume the corresponding risks.