The first proviso to Section 147 restricts reassessment initiated after four years from the end of the relevant assessment year where the original assessment was completed under Section 143(3). Reopening is permissible only where escaped income resulted from the assessee's failure to fully and truly disclose all material facts. Disclosure of complete share-sale transaction particulars during the original scrutiny assessment, coupled with recorded reasons that do not allege such failure, does not satisfy the statutory condition for reopening beyond four years.

Statutory approval under Section 151 for reassessment requires the approving authority to independently consider recorded reasons and supporting material; a bare "fit case" endorsement is mechanical, invalidates the sanction, and leaves reassessment without jurisdiction. Reassessment is not a change of opinion where subsequent investigation information concerning accommodation entries was unavailable during the original assessment. Alleged bogus-purchase additions require probative and corroborative material: invoices, stock, payment, transport, and undisproved sales records cannot be displaced solely by an untested supplier statement or cash withdrawals lacking a transaction nexus. Estimating a profit element also requires cogent proof of suppressed profit.

Revision under Section 263 requires both an erroneous assessment order and prejudice to the Revenue; it cannot rest solely on a different view where the Assessing Officer has examined the supporting material and adopted a legally plausible view. Interest awarded under Section 28 of the Land Acquisition Act, 1894 is treated as an accretion to compensation for compulsory acquisition, rather than as separate interest. It therefore retains its capital-gains character and, where agricultural-land conditions are satisfied, qualifies for exemption under Section 10(37) instead of taxation as income from other sources.

Unexplained-expenditure and unexplained-money additions require foundational proof: section 69C requires evidence that the assessee incurred expenditure, while section 69A requires proof of ownership of unrecorded money or specified assets. A loose sheet seized from a third party and that party's untested statement cannot, without independent nexus and corroboration, establish either fact. Possession-based presumptions apply to the person from whom material is seized and do not automatically extend to another person. Appellate scrutiny of the existing assessment record, without admitting identified fresh material, is an evidentiary appraisal rather than admission of additional evidence.

Tax additions for alleged unexplained loans, receipts, interest income, and unaccounted flat-sale consideration require reliable evidence linking the assessee to actual unrecorded transactions. Third-party electronic records engage statutory possession presumptions only against the person from whom recovered and cannot be used against another person without an independently established nexus; denial of cross-examination and retracted, uncorroborated statements weaken their evidentiary value. A foundational unrecorded investment or actual interest accrual must be proved before income is assessed. Median-rate estimates and project-wide extrapolation cannot replace recorded sale consideration where books remain unrejected and no buyer-specific evidence, unaccounted cash, or corroborative transaction records establish cash receipts.

Section 68 additions for unsecured loans cannot rest on delayed or absent verification responses where identity, creditworthiness and genuineness are established through confirmations, banking records, financial information and repayments; the additions were deleted. Interest disallowance for non-business diversion requires a direct nexus between borrowings and non-business use; availability of sufficient interest-free funds defeated the disallowance. Borrowing-related brokerage and processing costs remain business expenditure absent proof of non-business nexus, bogus claims or enduring capital advantage. Rule 8D requires examination of accounts and objective dissatisfaction with the taxpayer's claim; recomputation must include only investments producing positive exempt income. Receipts reconciled between Form 26AS and proprietary-concern books cannot be taxed again, as that would cause double taxation.

Offshore supply receipts under separately executed offshore, onshore supply and onshore service contracts remain outside Indian taxation where property and payment pass outside India and no operations generating that income occur in India. CIF terms, custody obligations, performance guarantees and acceptance testing do not, by themselves, alter that result. A fixed place permanent establishment requires a place at the foreign enterprise's disposal, while a dependent agent permanent establishment requires dependent agency and requisite authority. An Indian associate conducting substantial independent business and attending limited meetings for its own onshore scope does not establish a permanent establishment, business connection, or profit attribution. Section 44BBB does not cover standalone offshore supplies with offshore transfer of property absent taxable Indian operations.

Section 153C jurisdiction requires a satisfaction note to identify how seized incriminating material relates to each relevant assessment year. Mere recording of a seized hard disk and a proposal to initiate proceedings for specified years, without a year-specific nexus, is insufficient. Proceedings initiated on such vague satisfaction are invalid, favouring the assessee.

Modified returns furnished after a business reorganisation, where no assessment or reassessment proceeding is pending, permit only modification of total income already determined to implement the reorganisation order. Such returns do not operate as returns under Section 139 capable of triggering fresh scrutiny under Section 143(2). Section 170A distinguishes completed assessments from pending proceedings: Section 170A(2)(a) applies to completed assessments, while Section 170A(2)(b) permits assessment or reassessment only where proceedings remain pending. Section 170A(3) does not expand jurisdiction. Verification may be limited to ensuring proper implementation, but de novo scrutiny and consequential transfer-pricing proceedings lack jurisdiction.

Section 10B deduction for an export-oriented unit should not be reduced through a blanket turnover-based allocation of expenditure where the unit maintains separate audited accounts, registration, factory facilities and production arrangements. Material differences in product mix, fixed assets, manufacturing process, power consumption, interest burden and tax incidence supported unit-wise expense allocation. In the absence of any identified discrepancy, and where profitability remained broadly consistent with the preceding year, allocating all expenditure solely by sales turnover was unsupported. The claimed deduction consequently remained sustainable.

Statutory limitation under Sections 153A and 153C permitted an extended ten-assessment-year period where alleged escaped income exceeded the prescribed threshold. The period was calculated backwards from the assessment year in which the satisfaction note was recorded. With the satisfaction note recorded in assessment year 2022-23, the extended period reached only up to assessment year 2013-14. Assessment year 2010-11 therefore fell outside the permissible period, rendering the assessment order time-barred.

Revisionary jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to the Revenue. Where reassessment followed notices, explanations and supporting material furnished by the assessee, revision cannot rest solely on the same portal information already examined. A perceived need for further inquiry is insufficient unless the revisional authority identifies a lack of inquiry, a specific error or discrepancy in the assessee's material, and resulting prejudice to the Revenue. In these circumstances, the prerequisites for revision were not met and the revisionary order was invalid.

Income-tax processing, rectification and revision must consider all material particulars disclosed in the return and provide reasons. A computation addressing only receipts and an exemption claim while disregarding reported expenditure reflects non-application of mind. A rejection of rectification without reasons is similarly defective. The intimation and the rejections of rectification and revision were set aside, with fresh consideration of the rectification application required in light of the return and relevant observations.

Reassessment founded on an audit objection alleging a health and education cess deduction requires verification that the deduction was actually claimed; an unverified factual premise demonstrates non-application of mind and cannot support reopening. Interest on borrowings invested in a subsidiary remains allowable where the investment is commercially expedient and connected with business purpose. Business purpose is not limited to the taxpayer's immediate profit-making activity, and the Revenue cannot replace a prudent businessperson's commercial judgment. Consequently, neither objection supplies a sustainable basis for reassessment.

Section 260A confines interference with the Tribunal's factual findings to a substantial question of law; evidence cannot be reappreciated unless findings are perverse, unsupported by evidence, or disregard material evidence. For Section 68 share-sale credits, investment and sale records, bank statements, purchaser confirmations, returns, audited accounts and notice responses were assessed cumulatively, and the record did not establish that the proceeds represented undisclosed money. Human probabilities and surrounding circumstances inform evidentiary assessment but cannot justify an addition solely on suspicion or general allegations against purchasers. Earlier acceptance of investments remains relevant, though it does not bar scrutiny of later sales. No substantial question of law arose, sustaining deletion of the addition.

Section 69A addition for alleged unexplained money cannot rest on uncorroborated search or survey material, a promptly retracted statement, or suspicion, conjecture and surmise. Although technical evidence rules do not strictly apply in income-tax proceedings, relevant independent material is required before drawing an adverse inference, consistent with natural justice. Because the brokers' material related to an earlier period and no broker statements or other evidence established investment or interest income, the deletion was sustained and no substantial question of law arose.

Reassessment under section 147 read with faceless assessment provisions raised the issue whether the Assessing Officer could proceed with assessment after issuing a notice under section 143(2). The special leave petition was dismissed without interference with the High Court's order, leaving the challenged reassessment ruling and the Assessing Officer's jurisdiction to proceed undisturbed.

Proceedings under section 153A were challenged because the approval under section 153D was allegedly vitiated by total non-application of mind. The Supreme Court declined to interfere with the High Court order and dismissed the Special Leave Petition, leaving that order undisturbed.

Jurisdiction over scrutiny notices under section 143(2) arises where one tax officer issued the notice and another completed the assessment under section 143(3). The central issue is whether an assessee may challenge either officer's authority despite provisions that cure certain procedural defects and limit objections to notice defects. Sections 292B and 292BB are relevant to the validity of the notice and the resulting assessment. Questions concerning the officers' respective jurisdiction and the operation of these defect-curing provisions remain for consideration in appellate tax proceedings.

Limitation for completing a fresh assessment after remand arose under sections 153(3) and 153(4), including whether failure to complete the assessment within the prescribed period results in deemed acceptance of the return. The Supreme Court declined to interfere with the High Court's judgment and dismissed the special leave petition, leaving that judgment undisturbed. Pending applications were also disposed of.