Final settlement under the Vivad Se Vishwas Scheme conclusively closes the assessment dispute concerning the relevant tax arrears. Once the competent authority issues a full and final settlement order, the underlying assessment cannot be reopened through revisionary jurisdiction under Section 263. Revisionary proceedings initiated after such settlement are therefore impermissible, and the original assessment remains restored.

Bank-account credits arising from agricultural-loan disbursements and recoveries cannot, without further factual material, support a presumptive-profit addition at 8%. Correspondence between substantial withdrawals and deposits, together with the entity's registered cooperative lending activities, supports the explanation that the entries represent loan flows rather than business receipts. In the absence of evidence of another business activity or a factual basis for the profit estimate, the addition was unsustainable and deleted.

Post-search assessments for preceding assessment years covered by Explanation 2 to section 148 must follow the special reassessment mechanism under sections 147 and 148. The deeming fiction of escapement of income displaces direct scrutiny assessment under section 143(3); neither administrative selection nor taxpayer participation can cure the absence of a jurisdictional reassessment notice. Prior approval under section 148B is mandatory before assessment, reassessment, or recomputation and requires independent consideration of relevant seized material. General supervisory or administrative approval cannot substitute for this statutory safeguard. Non-compliance with either requirement renders the assessment void for lack of jurisdiction.

Section 14A read with Rule 8D does not permit disallowance of expenditure relating to exempt income where no exempt income was earned or received in the relevant year. For Assessment Year 2017-18, this rule precludes the proposed disallowance. The Finance Act 2022 amendment applies prospectively from Assessment Year 2022-23 and does not affect the earlier year.

Section 68 treatment of unlisted-share sale proceeds requires consideration of supporting transaction records, including PMS registration, portfolio and capital-gains statements, valuation documentation and demat delivery instructions. Non-disclosure in a return schedule, without contrary material or a valuation defect, does not by itself displace evidence of purchase and sale. Corporate filings and shareholder records may substantiate original subscription cost and indexed acquisition cost despite unavailable historic bank slips. A partner's share of LLP profit, accepted as such, is exempt and cannot be treated as unexplained cash credit.

Section 69A applies only where the source of money is not satisfactorily explained. Contemporaneous cash withdrawals, returned income, rental income and property-sale proceeds may together establish the availability and source of funds for a cash deposit, preventing its treatment as unexplained money. Delay in filing an appeal may be condoned on sufficient cause where an appellate order went unnoticed during a tax professional's illness and the taxpayer acted promptly after learning of the outstanding demand.

Political-contribution deductions require a genuine contribution. Banking-channel payments and donation receipts do not by themselves establish genuineness where investigation material, physical verification, recipient party non-compliance, and fund layering indicate an accommodation-entry arrangement. Applying human probabilities and preponderance of probabilities, the claimed donation did not represent a genuine political contribution. The deduction claimed under Section 80GGC was therefore disallowed.

Revision under Section 263 requires an assessment order to be both erroneous and prejudicial to the Revenue's interests. Construction expenditure treated as unexplained investment had been examined by the Assessing Officer and brought to tax in subsequent assessment years. Since the expenditure was already assessed in those years, no further addition was warranted in the earlier assessment year. The conditions for invoking revisionary jurisdiction were therefore not satisfied, and the revision order was quashed.

Unexplained-expenditure additions under the Income-tax Act require a sustainable evidentiary basis and cannot rest solely on an uncorroborated third-party statement when cross-examination is denied and statutory enquiry supports the taxpayer's explanation. Rule 46A governs the admission and verification of additional evidence, including opportunities for the Assessing Officer to examine the material. A payer's failure to deduct tax at source does not by itself alter the character of the recipient's receipts, because the deduction obligation rests with the payer. Books of account, payment records, job-work registers, delivery records and payer confirmations may corroborate disclosed job-work receipts.

Penalty under Section 271(1)(c) for concealment or furnishing inaccurate particulars is not attracted merely because an addition is made on a debatable issue. An addition relating to an area development fund involved a matter considered by the Supreme Court in comparable proceedings, supporting its debatable nature. Where relevant particulars were disclosed during assessment, the addition alone does not establish concealment or inaccurate particulars. Penalty on that addition is therefore not imposable and must be deleted.

Search-derived material following a Section 132 search triggers the special reassessment framework under Sections 147 and 148, including the deemed-information rule in Explanation 2 to Section 148. Where an assessment relies on that material and related statements, a pending Section 143(3) scrutiny cannot continue merely because a Section 143(2) notice was previously issued; the special mechanism prevails over the general scrutiny route. Section 148B separately requires prior statutory approval. Approval under an administrative CBDT instruction, even by the relevant approving authority, does not meet that mandatory requirement. Non-compliance renders the assessment unsustainable, leaving the Section 69C addition unexamined on merits.

Revisionary jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer specifically examines employee stock option scheme expenditure, considers supporting material and accepts the claim, a brief assessment order does not establish inadequate inquiry. Employee stock option discount may constitute employee compensation and deductible revenue expenditure under section 37(1). A pending challenge to precedent, without stay or reversal, does not alter that position. Revision cannot substitute the Principal Commissioner's view for a permissible view reached after inquiry.

Section 68 is inapplicable where purchases are capitalised as construction work-in-progress, no corresponding credit appears in the books, and purchase records are supported by tax filings, supplier evidence, invoices and audited accounts. Share application money is explained when the applicant's identity, creditworthiness and transaction genuineness are established through corporate, financial and banking records, absent material linking the assessee to alleged entry operators. Declared agricultural income is not unexplained credit where land ownership, production, sales and expenditure evidence substantiate cultivation and higher realisation is supported by the nature of the produce. The three additions were deleted.

Assessment of a company struck off and dissolved requires restoration of its legal existence through the prescribed corporate-law process before proceedings may be initiated or continued. Participation in proceedings does not cure the jurisdictional defect of assessing a non-existent entity. An outward bank remittance made through banking channels for import purchases is an application of funds, not unexplained money. Such an addition requires proof that the assessee owned unrecorded money or another specified valuable article; an unproved source of expenditure cannot replace that ownership requirement.

Reassessment requires the Assessing Officer to dispose of an assessee's objections to reopening by a speaking order before taking any further step. Issuing a notice for scrutiny assessment before deciding those objections constitutes proceeding with reassessment prematurely. Where the notice was issued while objections to the reopening remained pending, the reassessment proceedings and consequential reassessment order were unsustainable and were quashed.

Corporate guarantees issued for associated enterprises constitute international transactions and require arm's-length benchmarking, with the guarantee fee determined at 0.50% rather than 1%. Sales and marketing commission paid to a US associated enterprise is not subject to Indian withholding where it is not Fees for Included Services under the India-USA treaty; the corresponding disallowance does not apply. The Section 10AA deduction requires fresh examination of Form 56F, the bifurcated profit and loss account, and unit-wise eligible-profit computations, rather than turnover-based reallocation of common expenditure.

Penalty for misreporting under section 270A is unsustainable where the statutory notice fails to identify the particular circumstance of misreporting alleged under section 270A(9). Withdrawal of a political-donation deduction in the return filed after reopening, followed by acceptance of revised income in assessment, did not support the penalty. Precedent involving a notice that expressly specified the relevant section 270A(9) clause was distinguishable. The penalty was deleted.

Undisclosed income for search-penalty purposes includes unrecorded money, entries or transactions detected during a search and not disclosed beforehand. Reduction of a quantum addition alone does not remove its undisclosed or concealed character where the surviving amount remains unrecorded or concealed. The applicable minimum penalty rate under section 271AAB(1)(c) at the relevant time was 30%, not 60%. For section 271(1)(c), a penalty notice identifying concealment as the specific charge, supported by recorded assessment-stage satisfaction, can sustain penalty despite a reduced quantum addition.

Tax deduction at source default does not arise where an employer, while making leave fare concession reimbursements involving foreign travel, complies with an operative interim judicial direction requiring the reimbursement not to be treated as income for TDS. Although such reimbursements may be substantively taxable and ineligible for leave fare concession exemption, compliance with the binding interim direction precludes treatment as an assessee in default. A later declaration of the substantive tax position cannot retrospectively convert that compliant conduct into a default. Consequently, interest consequential to the alleged TDS default does not survive.

CBDT Instruction No. 1916 regulates jewellery seizure during searches but does not provide an unconditional exemption from assessment. Ownership, nature and source of jewellery must be established on the facts. Jewellery identified in the assessee's bedroom was assessable separately where the applicable benefit for the assessee and family had already been allowed, and jewellery found with brothers had been considered in their respective assessments. Joint occupation of a residence did not establish common ownership or permit unutilised family-member relief to be adjusted against the assessee's jewellery. The addition for unexplained gold jewellery was therefore sustained.