Reassessment approval for proceedings beyond three years was invalid because the proforma invoked Section 149(1)(b) despite alleging escaped income below the applicable threshold. Approval by the PCIT required demonstrable application of mind to the statutory conditions. Consequently, the order under Section 148A(d), notice under Section 148, and consequential reassessment were quashed.

Rebuttable presumptions under sections 132(4A) and 292C, together with search statements, do not independently prove personal beneficial ownership or taxable income. A seized cash worksheet found on a company employee's computer, without evidence of an individual's receipt, assets, expenditure, or financial trail, cannot establish that individual's undisclosed income. For a company, running cash entries may evidence off-book transactions but cannot make gross receipts wholly taxable where the worksheet includes payments, disclosed withdrawals, group-entity transactions, cash recycling, and unreliable balances. Taxable additions require a reliable nexus to the relevant transaction and identification of the net unaccounted income component; estimation at 25% was treated as permissible on the available evidence.

Acceptance of turnover and presumptive income under Section 44AD prevents an unexplained-expenditure addition under Section 69C merely because transportation details, GST particulars, cash-book entries, or purchase records are unavailable. Section 44AD does not require maintenance of books of account, and an addition cannot rest solely on missing supporting records where neither accepted turnover nor presumptive income has been disturbed. The specific nature of a facilitator's business does not by itself determine the validity of claimed purchases. Section 115BBE cannot sustain the consequential tax treatment where the Section 69C addition fails.

Section 80GGC permits deduction only for genuine qualifying political contributions. Banking-channel payments and donation receipts do not, by themselves, establish genuineness where investigation material, unrecanted statements, bank-trail analysis, and the recipient political party's established operating pattern show systematic accommodation-entry activity. The human-probabilities and preponderance-of-probabilities tests can establish that an apparent contribution does not reflect its real character, rendering the claimed donation ineligible for deduction.

Political-donation deductions under Section 80GGC require a genuine qualifying contribution. Banking-channel payments and donation receipts do not by themselves establish genuineness where investigation material, search statements, bank-trail analysis, and evidence of systematic layering indicate that a political party was used to provide accommodation entries. Applying human probabilities and the preponderance-of-probabilities standard, apparent documentation may be rejected when the surrounding evidence shows that the transaction was not real. A non-genuine political donation does not qualify for deduction under Section 80GGC.

Long-term capital gain exemption claims involving penny-stock shares require substantiation beyond stock-exchange routing and banking records. Under Section 68, abnormal price appreciation, lack of comparable investment activity, unrebutted investigation material, and inability to establish share acquisition may support treating the receipts as unexplained cash credits, with tax consequences under Section 115BBE. Disclosure of share transactions in the return does not establish their genuineness where surrounding evidence indicates accommodation entries. Where the underlying addition for a non-genuine transaction is sustained, penalty under Section 271(1)(c) may also arise. The evidential burden is assessed on the preponderance of probabilities.

Cash deposits attributed to Banking Mitra transactions require verification of bank records, appointment documents, transaction particulars and commission statements before they may be treated as unexplained money under section 69A and taxed under section 115BBE. Where the explanation is that only commission income accrued, de novo adjudication with a reasonable hearing is required to determine the deposits' nature and source. A penalty under section 271AAC(1) founded solely on that addition cannot continue once the quantum addition is set aside, although fresh penalty proceedings may follow the reassessment outcome if warranted by law.

Section 2(15) treats education as a charitable purpose, while Section 12AB registration examines an institution's objects and the genuineness of its activities. Substantial fees and surplus generated through educational activities do not, by themselves, establish a profit-making purpose where the surplus is applied or accumulated for educational objects and is not diverted to non-charitable purposes or members' benefit. Delay in filing Form 10AB may be condoned where the applicant submits a condonation request supported by an explanation. These principles support renewal registration for a qualifying educational society.

For AY 2016-17, reassessment notice under Section 148 was time-barred because the extended limitation period under Section 149(1)(b) required escaped income to meet the prescribed threshold. The recorded escaped-income figure included a cash-deposit amount twice: once separately and again within total cash deposits. Removing the duplicate entry reduced the alleged escaped income below the threshold, leaving only the ordinary limitation period under Section 149(1)(a). The notice was therefore invalid, and the reassessment lacked jurisdiction.

Interest on fixed deposits and Kisan Vikas Patras, although taxable as income from other sources, forms part of a partnership firm's book profit for calculating the ceiling on partners' remuneration when credited to its profit and loss account. Explanation 3 to section 40(b) uses the net commercial profit disclosed in that account, rather than limiting book profit to income assessed under profits and gains of business or profession. Such interest cannot be excluded from the remuneration computation, and any consequential disallowance is not sustainable.

Rectification is confined to correcting a mistake apparent from the record and cannot be used to review or reopen an issue requiring reconsideration. Where an appeal was not admitted because delay in filing was not condoned, a rectification application must identify an apparent error in that refusal. As no such mistake was established, rejection of the rectification application remained valid. Claims concerning the merits of the deduction and consequential interest fell outside the rectification dispute and were not adjudicated.

Ad hoc disallowance of business expenditure lacks support where audited books remain unrejected and no identified item is bogus or unsupported; differing descriptions in ledgers, supported by cash-book details and vouchers, do not by themselves justify a blanket disallowance. Cash payments attracting deduction restrictions require verification of each recipient, business expediency, and any applicable Rule 6DD(e) exception for specified animal-husbandry produce, including hides and skins. The expense disallowance was removed, while the cash-payment issue was remitted for fresh verification and recomputation.

Estimated additions for alleged on-money receipts from flat sales under Section 69A cannot be sustained without corroborative evidence that the assessee received the alleged amounts. Seized material supported specified on-money receipts, which the person managing the project accepted and offered to tax. Further additions based on applying an average sale rate to other flat sales lacked material connecting additional on-money to the assessee. Such uncorroborated estimation does not establish unexplained money under Section 69A, and the estimated additions are deleted.

Cash-deposit additions under section 69A require assessment of whether deposits represent income rather than gross receipts. Self-prepared and unaudited cash records, bank material and related documents did not support full acceptance of the explanation, but also did not justify treating the entire cash deposit as unexplained income. The addition was confined to an estimated profit component of 10% of the deposit, taxable at normal rates rather than under section 115BBE.

Interest received by an agricultural co-operative society from investments with a co-operative bank qualifies for deduction under Section 80P(2)(d). The provision covers interest or dividend income received from investments with another co-operative society, and a co-operative bank remains a co-operative society for that purpose. Section 80P(4) excludes a co-operative bank from claiming the deduction itself; it does not prevent another co-operative society from claiming deduction for interest earned from that bank. Such interest therefore remains deductible under Section 80P(2)(d).

Under-reporting of income requires a comparison between assessed income and income determined on processing the return. Where income disclosed in the original return, accepted on processing, is repeated in reassessment and accepted without additions or disallowances, the statutory conditions for treating that income as under-reported are not met. Penalty for under-reporting is therefore unsustainable in the absence of any variation between the processed and reassessed income.

Mandatory corporate social responsibility expenditure is excluded from business-expense deduction under Section 37(1), but that exclusion applies only to computing business income. Donations within such expenditure may independently qualify for deduction under Section 80G where they satisfy its conditions. Revision under Section 263 requires both an erroneous assessment order and prejudice to the Revenue. Where the Assessing Officer has sought and reviewed deduction particulars and receipts, the claim has been examined with application of mind; adoption of a legally sustainable view does not make the assessment erroneous. Revision therefore cannot displace the Section 80G deduction for qualifying CSR donations.

The final assessment order following DRP directions was governed by the procedure under section 144C rather than the limitation applicable to the draft assessment order, and was therefore not time-barred. For the relevant assessment year, permanent establishment had to be determined under Article 5 of the applicable India-UK tax treaty; inapplicable MLI provisions or their underlying spirit could not be invoked. Dependent-agent, fixed-place and service PE required separate treaty-specific examination of contractual arrangements, conduct, and functions, assets and risks, with the Revenue bearing the burden of proof. Profit attribution required FAR analysis and could not rest on an ad hoc percentage; arm's-length remuneration could eliminate further attribution if fully compensatory.

Reassessment notices issued more than three years after the end of the relevant assessment year require prior sanction from the higher authority specified under the applicable reassessment regime. Approval by the Principal Commissioner is insufficient where approval from the Principal Chief Commissioner, Principal Director General, Chief Commissioner or Director General is required, leaving the notice without valid jurisdiction. Time for responding to a notice cannot be excluded from limitation where no extension was sought. A non-speaking dismissal of a Special Leave Petition does not trigger the doctrine of merger or affirm the High Court's reasoning.

Section 148 permits use of search-derived information only where seized material bears a prima facie, live and relevant nexus to the assessee and alleged income escapement. A loose paper recording only a survey number, rate and an unrelated broker's name, predating the taxpayer's purchase and not naming the taxpayer or vendors, lacked that nexus. Subsequent public land-record information and prospective application of the stated rate could not cure its vagueness; the reassessment notice was therefore invalid.