Loan credits are satisfactorily explained under section 68 when lender identity, prima facie financial capacity and transaction genuineness are supported by confirmation, identifiable bank transfers, financial records and repayment material. General, untested allegations concerning a lender's activities do not rebut transaction-specific evidence without inquiry or material linking the credit to an accommodation entry. Section 69C cannot support an inferred commission addition without proof that expenditure was actually incurred and its source remains unexplained. Interest disallowance cannot rest solely on an unexplained-loan premise that fails, particularly where no separate interest deduction is claimed under the presumptive scheme in section 44ADA.

Articles 6 and 7 of the Multilateral Instrument require incorporation into domestic law through a specific notification under section 90(1) before they can modify India-Ireland DTAA benefits. Without such incorporation, the Principal Purpose Test cannot restrict treaty relief. Valid tax residence, commercial substance and cross-border aircraft leasing do not, by themselves, establish a principal purpose contrary to the treaty's object and purpose. Dry-lease rentals for aircraft used in international traffic fall within Article 8(1) where the lessor operates from Ireland and the aircraft is not at its disposal as a fixed place of business; standard lessor protections do not create a permanent establishment. Retained ownership and repossession rights indicate an operating lease, so rentals are not interest income.

Section 43CA's enhanced 10% tolerance band is treated as a curative measure mitigating hardship from deemed-consideration rules and applies retrospectively to assessment year 2016-17. Transfers with differences within that band do not attract additions based on stamp-duty value. For Flat A-702, the claimed 2011 allotment and banking-channel receipt require verification to determine whether agreement-date stamp value may apply. Where stamp valuation is specifically disputed as exceeding fair market value, statutory verification and, where warranted, reference to the Valuation Officer are required before deemed consideration is determined.

Giving-effect orders implementing an approved corporate insolvency resolution plan recomputed taxable income at nil and eliminated tax demands for the relevant assessment years. Revenue claims not included in the resolution plan were treated as extinguished, reflecting the plan's binding effect on statutory authorities. Consequently, the revenue's and assessee's cross-appeals no longer required adjudication and became infructuous.

For search-related assessment years beyond six years, the transitional bar in the first proviso to Section 149 requires that a notice could also have been issued under the pre-Finance Act 2021 search-assessment regime. The extended period under Sections 153A and 153C applies only where available material reveals escaped income represented by a prescribed-value qualifying asset. Alleged unexplained cash receipts and cash expenditure under Sections 69A and 69C, without evidence of such an asset, do not satisfy that condition. A search statement alone does not establish the separate asset requirement; extended limitation was therefore unavailable and reassessment invalid.

Separate estimated profit on subcontract expenditure is unwarranted where the underlying contract receipts and profit are already recorded and taxed, as it duplicates taxable income; bank payments and tax deduction at source support the recorded transactions. Donation deductions require receipts and evidence of payment to an eligible institution, so unsupported claims remain disallowable despite banking entries. Provident-fund late-payment interest is compensatory and allowable, whereas damages are penal and non-deductible; where records do not segregate them, the claim requires verification and recomputation.

Holding period for an identified flat acquired under an allotment arrangement runs from the allotment date where enforceable property rights arise and payments are made under that arrangement, rather than from subsequent conveyance registration. The asset may consequently qualify as a long-term capital asset, with indexation and deduction under section 54 available in accordance with law. For section 56(2)(vii)(b), an allotment letter containing material acquisition terms may constitute an agreement. Where consideration is paid through non-cash modes on or before that date, stamp-duty value must be determined as of the allotment or agreement date, requiring valuation-based income to be recomputed on that basis.

Transfer-pricing comparability requires functional alignment across services, scale, business model and intangibles. Entities with diversified integrated operations, significant brand value, or accounting, publishing and platform services are unsuitable for routine captive IT-enabled services, whereas functionally similar IT-enabled providers may remain comparable despite absent segmental data. Companies satisfying applicable filters cannot be rejected merely because they are absent from the TPO search matrix; annual reports and FAR analysis require verification. Associated-enterprise receivables are international transactions requiring separate arm's-length benchmarking after the allowed credit period, using LIBOR plus 200 basis points following 60 days. Foreign-exchange gains on restated export receivables and payables lack the direct and proximate export-income nexus required for Section 10AA deduction.

Sanction for reassessment under Section 151 requires the competent authority's independent application of mind before notice is issued under Sections 147 and 148. A statement that a case is fit for notice, based solely on the Assessing Officer's recorded reasons, is a mechanical endorsement rather than valid statutory approval. Summary dismissal of related special leave petitions does not create binding law or trigger merger. Invalid sanction results in quashing the consequential reassessment.

Section 151 approval for a reassessment notice must reflect independent, meaningful consideration of the material and statutory requirements; merely endorsing the Assessing Officer's reasons or stating that notice is fit for issue is mechanical and insufficient. The sanction requirement operates as a substantive safeguard even where approval is administrative, requiring reasons and application of mind. Conflicting non-jurisdictional High Court views remain unresolved by summary dismissal of special leave petitions, which neither triggers merger nor establishes binding law. Applying the interpretation favourable to the assessee, mechanical approval invalidates the sanction and requires quashing the consequential reassessment.

Tax deducted at source credit must be claimed for the assessment year in which the corresponding deduction is reflected in Form 26AS. Where tax was deducted during financial year 2022-23 and appeared in Form 26AS for assessment year 2023-24, credit was not available for assessment year 2024-25 through rectification under Section 154. Reliance on Section 155(20), Rule 134 and Form 71 did not cure the assessment-year mismatch.

Revision for inadequate inquiry may apply where a deduction for contributions to a Core Settlement Guarantee Fund is allowed without examining whether the payment discharges an accrued and ascertained liability or creates a contingent reserve. Explanation 2(a) treats an assessment as erroneous and prejudicial to Revenue when required inquiry or verification is absent. Examination should address whether the contribution augments a corpus for possible clearing-member defaults, whether interest is earned from that corpus, and whether any identified default has crystallised a liability. Deductibility as revenue expenditure requires independent examination, and a limited revision may direct fresh verification.

Business deductions for motor vehicles registered in a director's name require records demonstrating exclusive company use; absent such evidence, a 25% disallowance for personal use applies, notwithstanding treatment in an earlier assessment. Interest on borrowings remains deductible where the borrowings are used for business purposes and no nexus is established with interest-free advances, particularly where those advances are funded from interest-free sources. Rent for director-provided accommodation may be commercially expedient and deductible, while the director's perquisite is separately taxable. Bank penal interest for delayed loan instalments is compensatory, rather than payment for an offence or prohibited purpose, and is allowable under section 37(1).

Section 14A permits Rule 8D computation only where recorded, account-based dissatisfaction establishes that a voluntary exempt-income expenditure disallowance is incorrect; a formula-only objection is insufficient. For assessment year 2020-21, depreciation is available on goodwill, brands and distribution networks identified and acquired for apportioned consideration in a demerger, even if absent from the demerged entity's asset block. Restrictions applicable to existing block assets do not cover these newly identified intangibles, and the later goodwill exclusion applies prospectively. Donation deductions disclosed in returns and audit records require consideration once assessment adjustments yield positive gross total income, notwithstanding losses in the returned computation.

Rule 27 allows a respondent that has neither appealed nor filed a cross-objection to defend an appellate order on a ground decided adversely, including a jurisdictional challenge to reassessment. Where alleged escaped income is based solely on search material and the year falls within the extended relevant assessment years under Section 153A, that provision's non obstante clause and mandatory language make it the exclusive assessment mechanism. If the extended-regime conditions, including the prescribed asset threshold, are met, recourse to Section 148 is without jurisdiction and the resulting reassessment is void ab initio.

Section 250 requires the first appellate authority to decide an income-tax appeal on merits by formulating points for determination and recording reasons. Dismissal solely because the assessee is absent or fails to file written submissions, including in an ex parte proceeding, does not meet that statutory duty. Where a prior direction requires merits-based reconsideration, compliance with these requirements is mandatory. An appellate order lacking points for determination and merits-based reasons is legally unsustainable and requires de novo reconsideration after reasonable opportunity of hearing.

Challenges to the legality, validity and propriety of a reassessment notice, including the statutory sanction for its issuance, were left open after connected reassessment matters were remanded. The petition was closed with liberty to initiate fresh proceedings on the same cause of action, including a challenge to the newly introduced statutory provision. Existing protection continued for 90 days but would cease if no fresh petition was filed within that period.

Section 275(1)(a) requires penalty proceedings under Section 270A to remain in abeyance while an appeal against the relevant assessment order is pending before the Appellate Tribunal. Where the appeal was filed and remained pending when the penalty order was issued, the order contravenes that requirement and cannot stand. The Assessing Officer's awareness or lack of intimation of the pending appeal does not affect this consequence.

Interest on requisitioned cash accrues under Section 132B(4) at simple interest of one-half per cent for every month or part of a month, from the day after expiry of 120 days following execution of the requisition until completion of assessment. Where assessment determines no tax liability, Section 132B(3) requires forthwith release of remaining seized assets. Continued post-assessment retention may attract compensatory interest on restitutionary principles despite no express statutory provision for that period. Compensation for deprivation of the use of money does not depend on whether the Revenue earned interest on the retained cash.

Effective cross-examination must be provided before completing a fresh assessment where prior directions require witnesses to be made available in accordance with principles of natural justice. An assessee's failure to attend an initially fixed hearing does not exhaust that right when the Assessing Officer subsequently issues fresh notices to the assessee and witnesses; those notices condone the earlier lapse. If the assessee attends the rescheduled hearing but witnesses do not, assessment without cross-examination is vitiated. Fresh assessment must follow cross-examination of both witnesses, subject to stipulated witness costs.