Section 147 permits assessment of income discovered during reassessment only after the Assessing Officer assesses or reassesses the income forming the recorded basis for reopening. The expression "and also" operates cumulatively, and Explanation 3 does not remove that substantive condition. Where no addition or adverse finding is made on the share-transfer issue recorded for reopening, an unrelated addition for unexplained cash credit cannot be sustained in that reassessment. A fresh notice under Section 148 is required to pursue the unrelated income; otherwise, the reassessment is without jurisdiction and void.

Interest earned by a primary agricultural credit co-operative society on its own funds temporarily or statutorily invested with banks is attributable to its credit-facility business and qualifies for deduction under section 80P(2)(a)(i), provided the funds are not liabilities payable to members. The wider expression "attributable to" covers income having a business nexus, unlike the narrower "derived from" standard. Provisions for interest payable and audit fees are allowable business expenditure where they represent accrued, quantified liabilities connected with the business rather than contingent obligations. Taxable income requires recomputation after granting the eligible deduction and allowing those accrued liabilities.

Reassessment for alleged escaped income requires the Assessing Officer to identify the proposed addition in the notice under Section 148A(b), obtain prescribed approval, consider the taxpayer's response, and issue an order under Section 148A(d) before reopening. Where a proposed cash-deposit addition was considered and dropped after accepting the explanation, a later cash-deposit addition not identified in the notice or statutory order and lacking specified-authority approval failed to satisfy the mandatory procedure. The unsupported reassessment addition was therefore deleted.

Reassessment based on Investigation Wing information identifying accommodation entries can rest on tangible material where it is verified against financial records and an independent satisfaction of income escapement is recorded; this avoids borrowed satisfaction. Cash-credit additions require proper examination of lenders' confirmations, tax returns, financial statements and bank records to establish identity, creditworthiness and genuineness. Non-response to information notices alone does not dispense with that examination. Claimed lender declarations and related tax payments under the Vivad Se Vishwas Scheme require verification before determining the unexplained-credit issue.

The enhanced leave-encashment exemption ceiling under section 10(10AA)(ii) was set at Rs. 25 lakh with effect from 1 April 2023. Certification that the notification would not adversely affect any person supported application of the revised ceiling to non-government employees who retired before the notification was issued. Consistent application of the enhanced limit to similarly placed pre-notification retirees supported exemption for leave encashment up to the revised ceiling.

Section 14A read with Rule 8D does not permit disallowance of expenditure where no exempt income was earned, received, or receivable during the relevant previous year. For assessment year 2017-18, the absence of exempt income precluded any disallowance under these provisions, consistent with the binding jurisdictional position.

Reassessment initiated more than three years after the relevant assessment year requires escaped income meeting the statutory threshold. Although the order under Section 148A(d) alleged escaped income above INR 50 lakh, the final reassessment addition, computed at 2% of alleged accommodation entries, was INR 24,21,552. As the final addition fell below the applicable threshold under Section 149(1)(b), the reassessment proceedings and reassessment order were invalid and quashed.

Section 147 reassessment cannot rest solely on material already examined during a completed scrutiny assessment under Section 143(3). Where financial statements and furnished particulars were considered in the original assessment, reopening based only on the existing assessment record constitutes a change of opinion rather than a valid reason to believe that income escaped assessment. Fresh tangible material obtained after completion of the original assessment is required to support such reassessment; absent it, the reassessment proceedings are invalid and liable to be quashed.

Section 69A additions for jewellery require evidence beyond an ad hoc estimate. Customary ownership, including married daughters' streedhan retained at the parental home, may be established through affidavits, marriage photographs and applicable CBDT jewellery-holding guidance. Without departmental inspection, valuation, or cogent material connecting jewellery to undisclosed income, an addition is unsustainable. Likewise, documented bank withdrawals exceeding cash found can establish its source, preventing an unexplained-cash addition. Credible evidence of ownership and source therefore defeats unexplained-assets additions lacking contrary material.

Section 43B(d) requires actual payment for deduction of specified interest, but interest liability converted into cumulative redeemable preference shares under a corporate debt restructuring arrangement did not warrant disallowance. The applicable High Court precedent retained binding force because a pending special leave petition, without a Supreme Court stay, reversal, or modification, did not displace it. Consequently, the disallowance relating to the converted interest liability was deleted.

Settlement immunity under the Income-tax Act cannot extend to a prosecution instituted before the settlement application, even where the tax liability is resolved. That statutory bar does not displace inherent criminal jurisdiction to assess whether continuation of prosecution is justified. Where a settlement order is final, liabilities have been paid, no breach or challenge exists, and proceedings have remained pending for many years, continuation may serve no meaningful penal purpose and amount to abuse of process. The criminal complaint, summoning and consequential proceedings were quashed.

Section 127 requires recorded reasons for a transfer of jurisdiction and, where feasible, an opportunity of hearing; the hearing requirement is relaxed for transfers within the same city, locality or place. Following search-related group centralisation, assessees who sought or knew of centralisation, filed returns and participated before the transferee officer without timely objection may be treated as having waived technical natural-justice objections. Challenges concerning assessment notices, opportunity, and additions should ordinarily use the statutory appeal mechanism rather than writ jurisdiction where that remedy is effective. Group centralisation consequently remains operative, with assessment challenges to be pursued through statutory appeals.

Taxability of non-compete consideration was governed by an existing binding determination on corresponding receipts. Because the consideration fell within that established treatment, uniformity required the same tax result. The addition relating to the non-compete fee was therefore unsustainable and was deleted, with the substantial questions resolved in favour of the assessee.

Transfer-pricing comparability under Rule 10B requires assessment of market conditions, assets employed and risks assumed. As the Rules prescribe no statutory upper or lower turnover threshold, an upper turnover filter of Rs. 200 crore can be applied as a rational factual benchmark for determining the arm's length price. Interference with that comparability determination requires a specific showing of perversity. Application of the Rs. 200 crore upper turnover filter was treated as valid in the assessee's transfer-pricing analysis.

FCRA registration applications must fully and accurately disclose an organisation's character under Rule 9 and Form FC-3A; describing Zen Buddhist religious programmes as non-religious constitutes material misrepresentation and may justify refusal. Buddhist schools may qualify as religious denominations, while genuine structured teaching, research, preservation, or dissemination of Indian Knowledge Systems may be educational or cultural; worship or ritual activities require religious classification. Registration under Sections 11 and 12 is not a vested or absolute entitlement, and conversion-related activities may warrant denial. Refusal is reviewable only for perversity, failure to consider relevant material, or non-application of mind. Appeals from registration refusals under Section 31(2) are heard by a Division Bench.

Assessments founded solely on PAN-linked Form 26AS and risk-management data require disclosure of adverse material and independent verification when a taxpayer denies the reported transactions and alleges PAN misuse. Portal information, unsupported by inquiry from the alleged vendor or other cogent evidence, does not establish the taxpayer's connection with the transactions. Aggregating cash-payment and corresponding Form 26AS figures may duplicate alleged turnover. The Revenue bears the evidentiary burden to establish that connection. An appellate remedy may be ineffective where exceptional demands, required security or deposits, and accruing interest materially prevent access to relief. Fresh action must rest on cogent material and comply with applicable limitation requirements.

Material turnover discrepancies between VAT returns and income-tax accounts may support reassessment where VAT returns were not shown to have been disclosed during the original assessment. Reconciliation based on MRP reporting, duty, freight and local taxes requires factual verification in reassessment proceedings rather than writ review. A notice issued beyond four years may therefore rely on possible income escapement where full and true disclosure is not established. For notices issued before 1 April 2021, Section 148A does not apply; preliminary objections limited to jurisdiction do not require withdrawal where they concern reassessment merits.

Pre-amendment consideration for the sale of self-generated trademarks and trade brands is capital in nature but is not chargeable to capital gains where the cost of acquisition and improvement is unascertainable and no retrospective deeming rule applies. A dissolution clause providing indefinite, profit-linked payments may assign user rights rather than transfer ownership; subsequent consideration for ownership rights is therefore not royalty, annuity, or income from other sources. An arbitral award determining ownership and entitlement binds its parties unless evidence supports a colourable or non-genuine arrangement. Where the related tax addition does not survive, concealment penalty is not leviable.

Condonation of delay in electronically filing Form 10B under Section 119(2)(b) was granted despite substantial delay because the audit report had been physically signed within the prescribed period, the former accountant failed to upload it without the assessee's knowledge, and the lapse was promptly remedied after discovery. COVID-19 disruption and the death of the successor accountant supported the explanation. Payment of costs within the stipulated period sets aside the rejection and requires processing of the return as if Form 10B had been filed on time; non-payment results in dismissal of the writ petition.

Section 151A and the e-Assessment of Income Escaping Assessment Scheme require reassessment initiation, pre-notice inquiry, and issuance of reassessment notices to operate through automated, faceless allocation. Proceedings under Sections 148A and 148 are integrated and cannot be initiated separately by a Jurisdictional Assessing Officer under concurrent jurisdiction arrangements. Retrospective legislative validation is constitutionally ineffective where it merely overrides judicial determinations without curing the statutory defect on which those determinations rest, engaging separation of powers and rule of law concerns. A provision inserted into a repealed enactment after repeal lacks legal efficacy where savings provisions preserve only existing proceedings and the pre-existing statutory scheme.