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.

Section 260-A permits an appeal only where a substantial question of law arises. For transfer-pricing determination of the arm's length price of research and development services, functional comparability was undisputed. Exclusion of Neeman Medical International (Asia) Limited rested only on an assertion of consistent losses, but the financial material did not establish a consistently loss-making position. Its inclusion as a functionally comparable entity therefore did not raise a substantial question of law.

Penalty for under-reporting or misreporting is not attracted where a CSR-related deduction claim is supported by binding precedent and the underlying addition is deleted. An education cess deduction claimed under then-binding jurisdictional precedent, but relinquished after a retrospective amendment reversed that position, does not warrant penalty. Under the APA framework, timely filing of a modified return requires total income to conform to the agreement; a royalty adjustment thereby resolved, with complete disclosure, does not constitute under-reporting, misrepresentation or suppression. These principles exclude penalty where claims were legally supported when made and relevant transactions were fully disclosed.

Section 10(23FB) exemption applies where a trust is registered as a venture capital fund; separately maintained contributory schemes need not obtain individual registration. Submission of a scheme-specific private placement memorandum does not make the scheme an independently registrable fund. For the associated-company restriction, the shareholding test applies to trustees', settlors', sponsors' or directors' personal holdings, not shares held solely by trustees in a fiduciary capacity for the fund. This treatment preserves the fund's eligibility for the statutory exemption.

In a concluded assessment, additions under Section 153A require incriminating material found during search. Board resolutions, legal notes, valuation reports and related records concerning a firm's conversion, constitution and prior transactions do not meet that requirement where they disclose no undisclosed income; additions founded on them lack legal basis. Tax-neutral succession under Section 47(xiii) remains available where the business assets and liabilities existing immediately before succession vest unchanged in the company and partners receive only shares reflecting their pre-succession interests. Asset sales and changes in capital-sharing ratios before succession do not, by themselves, breach those conditions or justify denial of the Section 80-IA deduction.

Uncorroborated loose sheets containing scribbled figures cannot, by themselves, support an addition for undisclosed consideration in a property purchase. In a search assessment, such sheets are not books of account and require corroborative incriminating material. Without evidence of cash payment or of the availability and deployment of funds beyond the consideration recorded in the registered sale deed, the addition is unsustainable.

Section 148A(b) required that the assessee receive 30 days to respond before reassessment action. Curtailing that period to 15 days despite a timely extension request, when sufficient time remained for consideration, prejudiced the assessee's right to be heard. A reply uploaded before the Section 148A(d) order but not considered violated principles of natural justice. The Section 148A(d) order and consequential Section 148 notice were set aside, requiring a fresh decision after considering the reply in accordance with law.

Reassessment after a completed scrutiny assessment cannot revisit the existence of a permanent establishment where the issue was specifically examined, the taxpayer furnished detailed replies, and reopening relies on the same material. The absence of an express finding in the assessment order does not permit correction of an Assessing Officer's omission; such reopening constitutes a change of opinion and undermines assessment finality. Beyond four years, reassessment requires income escapement caused by failure to make full and true disclosure. Where subscription receipts and the Indian agent's role were disclosed during scrutiny, that condition is absent, and a notice issued after the applicable limitation period is time-barred.

Section 69 applies where investments are unrecorded in the books and the assessee fails to satisfactorily explain their nature and source; Section 115BBE governs the tax treatment of income assessed under that provision. Investments, loans and advances disclosed in the books and substantiated by bank records and audited financial statements, including brought-forward balances, do not support additions as unexplained investments. The Tribunal's factual assessment of those materials disclosed neither perversity nor illegality, so deletion of the additions did not give rise to a substantial question of law.

Recall of the writ proceeding was allowed. The revived petition was then closed, but the closure did not prevent institution of fresh proceedings on the same cause of action. Fresh proceedings may be instituted on that cause of action and may include a challenge to Section 147A. Existing protection was continued for 90 days.

Reassessment proceedings may be challenged afresh where a statutory amendment alters the basis for assessing-officer jurisdiction. Following the Supreme Court's remand approach, the earlier judgment was recalled and the writ petition was closed with liberty to initiate fresh proceedings on the same cause of action, including a challenge to Section 147A and consequential reliefs. Interim protection was continued for 90 days, but would cease if fresh proceedings were not commenced within that period.