Cash deposits made during demonetisation were examined under the unexplained cash-credit rule. Cash books and VAT records supported regular sales activity, and cash held before demonetisation was attributable to prior sales. Depositing that cash subsequently in bank accounts did not make its source unexplained. The deposits were treated as satisfactorily explained, requiring deletion of the addition under section 68.

Cash received and temporarily held for safe custody by a mediator in a property transaction does not constitute acceptance of a loan or deposit for section 269SS. Where affidavits, a registered sale deed and bank records establish that the amount was deposited into the mediator's bank account and promptly paid to the seller by cheque, the receipt falls outside the statutory prohibition. Alternatively, the bona fide nature of the arrangement constitutes reasonable cause under section 273B. Penalty under section 271D is therefore unwarranted and liable to be deleted.

Section 144C(13) requires a final assessment order following DRP directions to be completed within one month from the end of the month in which the directions are uploaded. Directions uploaded on the ITBA portal on 29 September 2021 required completion by 31 October 2021. A final assessment order passed on 24 November 2021 exceeded that statutory period, rendering it time-barred, void and set aside.

Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for conducting its business; group-wide filings and website information do not suffice. Dependent agency permanent establishment requires material showing that the subsidiary habitually concludes contracts, maintains and delivers stock, or habitually secures orders for the foreign enterprise. An independently operating manufacturer dealing on a principal-to-principal basis and bearing business risks does not satisfy these conditions. A royalty licensing arrangement does not establish agency for distinct offshore supply transactions. No profits from those supplies are attributable in India absent either form of permanent establishment.

Mandatory reversal of common GST input tax credit attributable to unsold units at Building Use Permission is treated as an irrecoverable project cost when post-completion sales fall outside output GST. Project-wise credit apportionment requires final adjustment by reference to the unsold portion, and the absence of fresh cash payment does not prevent deduction where a previously valid credit becomes unusable by law. The deduction arises in the assessment year when final statutory attribution crystallises, rather than earlier years when the credit remained available. A related reversal claim requires verification and must be allowed in only one appropriate assessment year to prevent double deduction.

Interest and other income earned by a co-operative society through deployment of funds not immediately required for member lending fall within income attributable to its business of providing credit facilities to members. The broader expression "attributable to", unlike "derived from", supports full deduction under Section 80P(2)(a)(i). Interest on amounts retained and payable to members is distinguishable because it arose in a different factual setting involving a claim under Section 80P(2)(d).

Section 87A rebate is available for assessment year 2024-25 against tax payable on long-term capital gains taxable under section 112, provided the prescribed total-income condition is met. Total income includes such gains, and neither section 87A nor section 112 expressly excludes the rebate for income taxed at that special rate. The specific exclusion in section 112A for certain gains does not extend to section 112 gains. The Finance Act 2025 restriction on rebate for income taxable at special rates is substantive and operates prospectively, so it does not affect assessment year 2024-25.

Revenue deductibility of Bio-Pharma Division expenditure depends on whether the business had been set up and was ready to perform its intended functions, rather than solely on the later commencement of commercial operations. Annual-report evidence of completion of the first project phase and commencement of production supports that status; later financial-enforcement events and uncertain segment-turnover allocation do not negate it for the relevant year. Blanket capitalisation of all divisional expenditure is inappropriate, since depreciation, interest on borrowed capital and scientific-research expenditure must independently satisfy their statutory conditions. On these facts, the full capital disallowance was unsustainable and deleted.

Section 68 treatment of share-capital and share-premium credits turns on evidence of the source, investor identity, creditworthiness and transaction genuineness. An accepted Income Declaration Scheme declaration may evidence the source of credited funds without conferring derivative immunity, and re-taxing income already taxed in the declarant's hands raises double-taxation concerns. For assessment year 2011-12, the later source-of-source proviso did not apply to closely held companies; however, fund trails suggesting circular routing of the assessee's own funds or cash-funded investor entities require verification. Reassessment may rest on specific search material establishing reason to believe, rather than borrowed satisfaction, even without a separate speaking order on objections.

Returns furnished in response to notices under section 148 issued before 1 April 2023 retain the character of returns required under section 139. The later third proviso to section 148, which denies that treatment to returns filed beyond the permitted period, does not apply to an earlier notice. Where a delayed return is filed during pending reassessment proceedings and is acted upon in computing assessed income, notice under section 143(2) remains mandatory. Non-issuance of that notice constitutes a jurisdictional defect rather than a curable procedural irregularity, rendering the reassessment invalid.

Capital-gains computation permits transfer brokerage and actual property-improvement costs where receipts, invoices or objective property records substantiate the expenditure. Non-retention of every invoice, particularly by non-resident owners, does not by itself justify rejecting otherwise supported improvement costs. For residential-property exemption purposes, a mandatory corpus-fund payment intrinsically linked to ownership forms part of the cost of the new property. Supplier invoices and payment receipts may establish qualifying expenditure even without a corresponding bank statement, absent contrary material. Labour and painting claims lacking identifiable bills, receipts or other reliable proof remain inadmissible. Capital gains and consequential exemption require recomputation after allowing substantiated expenditure and excluding unsupported claims.

Section 144C applies where an Assessing Officer proposes a variation in returned income through a draft assessment order on or after 1 October 2009, irrespective of the assessment year. For a remand requiring fresh adjudication by the DRP rather than consequential action, the fresh-assessment limitation falls under section 153(2A). Where a fresh transfer-pricing reference is made, the fourth proviso allows two years, running from departmental receipt or knowledge of the appellate order; internal movement or delayed receipt by the particular DRP does not defer it. Section 144C(13) regulates orders following DRP directions but does not displace section 153(2A)'s limitation, rendering proceedings after expiry unsustainable.

Undisclosed on-money additions require credible proof of actual receipt; unsigned draft agreements, incomplete settlement records and proposed transactions do not establish consideration for land not transferred. Protective additions require a corresponding substantive assessment arising from a genuine ownership or assessability dispute. Rejection of books of account requires material showing that declared results are unreliable; inadequate bills and vouchers may nevertheless justify a reasonable profit estimate. Section 50C applies only where the assessee transfers a capital asset, and a further capital-gains charge is unwarranted absent independent receipt of consideration when the same sale receipts have already been assessed as business income.

Section 69A places the burden on the assessee to satisfactorily explain the nature and source of seized cash. A categorical statement under Section 131 admitting individual ownership supported treatment of the cash as unexplained money. A later assertion that the cash belonged to the HUF and represented business funds required credible evidence linking the specific cash to that business. Historical bank withdrawals, alleged debtor recoveries and business advances were insufficient without a cash book, source records, confirmations, invoices or other reliable proof showing cash availability on the seizure date. The unexplained-money treatment was therefore sustained.

Search material revealing unaccounted business receipts supported reassessment notices and the related sanctions under Sections 149 and 151. Approval under Section 148B was not mechanical where the record reflected consideration of the draft assessment order, relevant material and correspondence. Profit from unaccounted receipts requires a reasonable, case-specific estimate; a 10% rate applies after credit for additional income already offered, while Income Declaration Scheme disclosures cannot be fully telescoped against such receipts. Section 79A bars set-off of business losses against undisclosed income arising from a search.

Penalty for concealment of income or furnishing inaccurate particulars requires a definite finding that income was concealed or that inaccurate particulars were furnished. Disallowance of depreciation or loss set-off claims, without material showing that the claims were false or that particulars were inaccurate, does not by itself attract penalty. Absence of supporting details and failure to challenge the related quantum disallowance likewise do not establish concealment or inaccurate particulars. Penalty therefore cannot be sustained solely because such claims were disallowed.

Section 56(2)(vii)(b) permits adoption of the stamp-duty value on the agreement date, rather than the registration date, where those dates differ and whole or part of the consideration was paid by a non-cash mode on or before the agreement date. Where an earlier agreement fixed the sale consideration and an unrebutted cheque payment preceded that agreement, the registration-date stamp value cannot sustain an addition under that provision.

Reassessment of a completed scrutiny assessment for alleged bogus long-term capital gains requires reasons to believe based on fresh tangible material, not a review of an issue already examined. Where share transactions, including purchase, demat and sale evidence, were scrutinised and the relevant gain was accepted, a later investigation report that does not identify the assessee or address existing material cannot establish income escapement. After the prescribed period, reopening additionally requires an uncontroverted failure to make full and true disclosure. On these facts, reassessment was invalid as a mere change of opinion.

For searches initiated on or after 1 April 2021, Explanation 2(i) to section 148 deems the Assessing Officer to possess information suggesting income escapement. The search-triggered route under sections 147 and 148 operates as the special statutory procedure and overrides regular scrutiny assessment under section 143(3). The Assessing Officer must discontinue section 143(3) proceedings and commence section 148 proceedings following such a search. Failure to follow that prescribed route creates a jurisdictional defect and invalidates the assessment.

Cash repayment of deposits otherwise than through prescribed banking modes contravenes the statutory restriction and attracts penalty. Relief based on reasonable cause requires the taxpayer to establish circumstances justifying cash repayment. Where amounts are claimed to be chit bid payments, the claimant must substantiate that they were paid to successful subscribers. Failure to deny cash repayments, prove the asserted chit payment character, or establish reasonable cause supports imposition of the penalty.