Section 12AA(3) permits cancellation of charitable registration only where activities are non-genuine or depart from the trust's stated objects. Alleged capitation fees based on inconsistent third-party loose sheets and statements, without corroboration from parents, students, institutional records, unexplained cash, or evidence of diversion, do not by themselves establish institutional non-genuineness. Isolated receipt-related allegations may instead be examined in assessment proceedings, including any denial of exemption where legally justified. An inherent-jurisdiction objection remains maintainable despite prior non-objection because consent, acquiescence, or waiver cannot confer jurisdiction; the underlying validity of the asserted jurisdiction requires separate adjudication.

De novo reassessment of an assessment completed under section 143(3) must be limited to the specific unsecured loans requiring examination. Where replies and supporting material were furnished, adverse inference related only to identified loans, and other loans were accepted, an appellate remand requires a rational nexus with the disputed issue. Reconsideration should not unsettle accepted findings without adverse material or findings against them. The remand is therefore confined to examination of the disputed unsecured loans, while accepted findings on the remaining loans remain undisturbed.

Search-based additions require corroborative evidence where a section 132(4) surrender is credibly reconciled; unsupported loose sheets and arbitrary commission extrapolation cannot alone establish undisclosed income or expenditure. Assessments of completed years under section 153A may proceed where search yields incriminating material. No section 14A disallowance arises without exempt income for the relevant year, and the 2022 Explanation is prospective. Depreciation on own-use trucks is calculated at 15% on correctly recomputed written-down value; section 35D capital employed excludes share premium but includes qualifying borrowings. Delayed-TDS interest is deductible as compensatory business expenditure. Salary, GDR expenditure and partnership-investment issues require evidence-based verification.

Section 50C(2) provides a statutory valuation mechanism where the stamp-valuation figure is claimed to exceed fair market value and prescribed conditions are met. Short-term capital gains require fresh determination after examining acquisition cost, acquisition date and relevant transaction records, which had not been examined. Where warranted, a reference to the Departmental Valuation Officer should be made and any valuation report considered. The computation must be redetermined after providing an effective opportunity of hearing, without expressing a view on its merits.

Transfer-pricing comparability for captive, limited-risk software-development service providers requires alignment of functions, assets and risks under FAR analysis. Diversified companies owning substantial brands, goodwill, patents and other intangibles, incurring significant research and development expenditure, and assuming substantial business and intellectual-property risks are materially different from cost-plus captive providers. Where standalone segmental information for comparable service activities is unavailable, such companies should be excluded from the comparable set. The transfer-pricing adjustment requires recomputation using functionally comparable entities.

For penalty purposes in reassessment, the return filed in response to a notice for reassessment is the relevant disclosure. Where that return discloses the gross receipts and income and the reassessment accepts the returned income without enhancement, addition or disallowance, no concealment or furnishing of inaccurate particulars arises from that return. Deemed concealment does not apply where an original return was filed and the relevant statutory explanation is not invoked. Penalty computation also cannot operate without a difference between returned and assessed income; penalty for concealment is therefore not leviable.

No separate transfer-pricing adjustment for notional interest on outstanding trade receivables is warranted where verification confirms that the taxpayer was completely debt-free during the relevant previous year. Although receivables may ordinarily require separate benchmarking under transfer-pricing rules, delayed recovery does not create an additional financing burden for an enterprise with no interest-bearing borrowings. Financial statements and relevant records must establish debt-free status; once established, the notional-interest adjustment must be deleted.

Tax audit obligations under the Income-tax Act do not extend to a State-funded university existing solely for educational purposes where its income is exempt under the statutory educational-institution exemption. Because the audit requirement does not apply in those circumstances, penalty for failure to obtain an accounts audit is not leviable and must be deleted.

Advertisement and publicity expenditure paid to third-party vendors for an entity's own business does not constitute an international transaction merely because it incidentally benefits an associated enterprise or its brand. An arm's-length-price adjustment requires tangible material establishing an arrangement or understanding to provide brand-promotion services to the associated enterprise. Carry-forward loss must correspond with the assessed income or loss and requires verification where the assessment order and computation sheet differ. Following amalgamation, a transferee may claim the transferor's TDS/TCS credit where the corresponding income is offered and assessed in the transferee's hands, subject to verification of the amalgamation scheme, tax credit and relevant income.

Minimum Alternate Tax credit under Section 115JAA may pass to an amalgamated company where a sanctioned amalgamation scheme transfers the amalgamating companies' tax rights and claims, including unutilised credit. Section 115JAA(7) specifically withdraws such credit on conversion of a private or unlisted public company into an LLP, but contains no equivalent restriction for amalgamation. That limited prohibition does not extend by implication to a transferee company succeeding to the tax attributes of amalgamating companies. Set-off remains subject to verification of the credit's quantum and legal availability.

APA methodology for administrative support services may guide arm's-length benchmarking in a year outside the APA and rollback periods when it covers the same international transaction and the functional, asset and risk profile and activities remain unchanged. Uniform allocation of actual costs without mark-up, supported by consistent group-wide allocation, supports that approach. An arm's-length price cannot be set at nil on an ad hoc basis after rejecting taxpayer benchmarking; the proposed Other Method must be properly applied and quantified. On these principles, no transfer-pricing adjustment arises for the service charges.

Omission of clause (i) of section 92BA without a saving clause removes the statutory basis for transfer-pricing adjustments founded solely on that provision. Mark-to-market losses on open equity and currency futures held as stock-in-trade may be recognised under the lower-of-cost-or-market valuation principle, including anticipated diminution in value on unsettled contracts. For disallowance relating to exempt income, interest-free own funds exceeding investments support the presumption that investments were made from those funds, excluding interest disallowance. Administrative expenditure should be computed only with reference to investments relevant to exempt income and after crediting voluntary disallowance.

Functional comparability governs benchmarking of business-support and general-management services between associated enterprises. Under the arm's length framework, comparables must reflect the functions performed, assets employed and risks assumed in the specific controlled transaction; use of the Transactional Net Margin Method does not remove this requirement. Healthcare or hospital operating entities cannot be selected solely because the service provider operates in the healthcare sector. Contractual terms, invoices and contemporaneous evidence must establish the services actually rendered and the precise functions performed. The arm's length price requires fresh determination using entities functionally comparable to the support and management services.

Settlement under the Direct Tax Vivad Se Vishwas Scheme, 2020, for an original assessment was confined to the disputed income from that assessment and did not extend to independently initiated reassessment proceedings or their separate addition. The reassessment addition for alleged purchases could not stand where the assessee was denied the identities of alleged counterparties, transaction-wise details, invoices, and other underlying material despite specific requests. Without disclosure of the factual foundation for the allegation, the assessee could not effectively rebut it; the addition was deleted.

Manufacturing scrap generated directly through eligible units' production qualifies for the profit-linked deduction. Further expenditure disallowance under section 14A and Rule 8D requires recorded satisfaction, based on the accounts, that a voluntary disallowance is inadequate; no additional disallowance is warranted where the voluntary amount exceeds exempt dividend income. Corporate guarantees for associated enterprises are international transactions, with the guarantee fee restricted to 0.35%. Equity investments at a premium cannot be recharacterised as deemed interest-free loans. Consistently applied incremental allocation of common expenses is accepted where separate books capture direct costs. Royalty benchmarking requires fresh determination after disclosure of the comparable-search strategy and an opportunity of hearing.

Arm's-length benchmarking of interest on debt instruments issued to an associated enterprise requires reliable comparability analysis of debt currency, borrower creditworthiness and market conditions; the transfer-pricing adjustment was deleted because no factual basis displaced the accepted methodology. Rule 8D may be invoked only after objective, account-based dissatisfaction under section 14A(2); generic references to administrative and employee costs did not satisfy that precondition, restricting disallowance to the voluntary amount. A notional Rule 8D disallowance cannot automatically support an Explanation 1 clause (f) adjustment to book profit under section 115JB, so the corresponding addition was deleted.

Expenditure is deductible in the year when the liability becomes ascertainable and crystallises, rather than the period to which the underlying cost relates. Where invoice details emerge only after a parent-company reconciliation following the prior year-end, no earlier provision is required for an unknown liability. Transfer-pricing benchmarking must reflect each tested segment's functions and transaction profile. Market-analysis and consulting services benchmarked under the Comparable Uncontrolled Price Method cannot be aggregated with captive back-office support services benchmarked under the Transactional Net Margin Method where material functional and economic differences exist. Separate segment-level benchmarking is required in those circumstances.

Technical know-how fees netted against the cost of premix purchased from an associated enterprise form part of closely linked transactions and may be aggregated under Rules 10A(d) and 10B. Where premix invoice prices are accepted under the comparable uncontrolled price method, the cost-reducing fee is treated as arm's length, precluding separate benchmarking and deleting the transfer-pricing adjustment. A Section 40A(2)(b) disallowance of directors' performance incentives requires evidence that expenditure is excessive or unreasonable against fair market value, business needs, or benefit derived. Without supporting findings or comparable evidence, the provision is not disallowable and the addition is deleted.

Share-trade disallowances founded on alleged accommodation entries are unsustainable where contract notes, demat delivery records, securities transaction tax payments and banking-channel transactions establish ordinary-course trades, with no material linking the taxpayer to accommodation entries. Under section 145(2) and ICDS-VIII, an approved demerger requires the original acquisition cost of shares to be apportioned between retained shares and securities allotted by resulting companies. Closing stock may therefore be valued using the substantiated post-demerger share cost rather than the unreduced pre-demerger cost, preventing distorted valuation. On those grounds, the identified trade disallowances and closing-stock addition cannot be retained.

Functional comparability under the Transactional Net Margin Method requires assessment of a comparable's actual business and financial profile for the relevant year. An entity performing infrastructure management, network operations, cloud computing, engineering and quality-assurance services alongside software development cannot be benchmarked at entity level against a software-development service provider where reliable segmental revenue and results are unavailable. Comparable margins must be recomputed in accordance with directions issued under section 144C(5) after verification and revision of the comparable set. Outstanding-receivable interest adjustments require verification of domestic balances and a transaction-specific arm's length rate based on the associated enterprise's financial standing, creditworthiness, and comparable uncontrolled terms.