Binding interim judicial directions restraining tax deduction on leave travel concession payments involving foreign travel override the employer's statutory withholding obligation for the period those directions remain operative. Although the underlying exemption was unavailable on the merits, a later decision resolving that issue could not retrospectively impose default liability where the employer complied with the interim directions. The employer therefore could not be treated as an assessee in default under section 201(1), and consequential interest under section 201(1A) was not chargeable.

Reassessment notices for Assessment Year 2015-16 issued on or after 1 April 2021 were required to be dropped because reassessment could not be completed within the limitation period prescribed by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. A notice issued under section 148 on 31 March 2022 was therefore time-barred, lacked legal authority, and could not confer jurisdiction on the Assessing Officer. The assessment founded on that notice was consequently quashed.

Rectification under section 154 is confined to errors that are obvious, patent and self-evident from the record. An alleged error involving inclusion of capital receipts, allowability of expenditure, and computation of taxable income following denial of exemption requires factual verification, legal interpretation and substantive adjudication; it is therefore outside rectification jurisdiction. As the same computation dispute was pending in the quantum appeal, it could not be reopened through rectification proceedings. The alleged computational error is not a mistake apparent from the record and is not rectifiable under section 154.

Compensation paid by a co-producer and director to settle film-production litigation was treated as business expenditure where the liability arose from professional obligations connected with timely project completion and commercial litigation in which the individual was personally impleaded. Consent terms and later judicial payment directions established that the liability had crystallised and had a sufficient professional nexus. The expenditure's true character, rather than its incorrect classification as bad debt in the return, governed deductibility. Lack of direct contractual privity under a later memorandum, earlier denial of liability, absence of recipient income, and the recipient's relationship with a production partner did not negate that nexus. Deduction was available under Section 37(1).

Cash deposits during demonetisation may be treated as unexplained investment where claimed accumulated salary savings are supported only by self-prepared statements, lack contemporaneous evidence and corresponding bank withdrawals, and subsequent transfers do not satisfy the test of human probabilities. However, an enhanced tax rate for unexplained income introduced prospectively does not apply to deposits made before its effective date. The addition remains sustainable, but tax must be computed under the law applicable when the deposits were made.

Section 56(2)(vii)(b) did not apply to an HUF where the sale agreement, patta and encumbrance certificate showed that its Karta acquired the immovable property in an individual capacity. The existing reassessment record was merely evaluated by the first appellate authority, so no inadmissible additional evidence was relied upon under Rule 46A. As the Revenue produced no cogent material that the HUF funded the purchase or that the property was an HUF asset, the HUF PAN's inadvertent inclusion in the sale deed did not establish ownership. The addition was deleted.

Permanent establishment status requires the Revenue to prove that an Indian office of an affiliated entity was at the foreign enterprise's disposal, used for its business, or habitually exercised authority to conclude contracts or secure orders on its behalf. The project office did not meet the conditions for either a fixed place or dependent agent permanent establishment. Separately contracted offshore equipment supply, repair and refurbishment performed outside India, with title passing outside India, lacked an Indian taxable nexus where the contractual separation was not shown to be artificial. Accordingly, offshore receipts were not taxable in India and no profit was attributable to an alleged Indian permanent establishment.

Section 56(2)(vii)(b) cannot apply retrospectively to an immovable-property purchase agreement executed before the provision commenced. Where the agreed consideration was supported by cheque payments, receipts and bank records, and part consideration was paid through banking channels before the agreement date, the stamp-duty valuation difference could not be taxed under the subsequently introduced charging provision. The stated analysis concludes that the addition was unsustainable and deleted.

Leave travel concession exemption under Section 10(5) is confined to travel within India and does not cover journeys involving a foreign leg, even where the domestic origin and destination are in India or reimbursement is limited to the shortest domestic route. An employer settling such claims with complete travel details must estimate employees' taxable income and deduct tax at source under Section 192(1). Pending proceedings concerning internal circulars do not alter this position, although recovery directions remain subject to the final outcome of related Supreme Court proceedings.

Penalty for underreporting is not automatic where a deduction claim rests on a genuine, bona fide explanation and was accepted in assessment and earlier rectification proceedings. The statutory exclusion for a genuine explanation applied, so the income was not treated as underreported and the penalty was deleted. A penalty notice and order must also identify the applicable statutory limb; a general reference to the penalty provision without specifying the relevant sub-clause makes the levy unsustainable. The alleged underreporting penalty was therefore deleted.

Balance sheet movements in Capital Work-in-Progress and pre-operative expenses do not constitute taxable income or revenue expenditure merely because account balances change. Capitalisation transfers to fixed assets are reclassifications, and reversals of duplicate entries neither create income nor represent deductible expenditure where no amount is charged to the Profit and Loss Account or claimed as a deduction. A reduction in a balance sheet asset cannot support an income addition without evidence of inadmissible expenditure, a claimed deduction, taxable remission or cessation, or a charging or deeming provision. The additions were therefore deleted as non-taxable accounting adjustments.

Section 13(1)(c), read with sections 13(2)(a) and 13(3), restricts the section 11 exemption only to trust income or property applied for the benefit of specified persons, including trustees. Where loans or advances to trustees constitute a violation, tax at the maximum marginal rate applies only to the income or benefit that enures to those persons; the remaining charitable income continues to qualify for exemption, subject to other statutory conditions. CBDT Circular No. 387 supports this limited denial approach, while Circular No. 5P and the Bharat Diamond Bourse decision do not require forfeiture of exemption for the trust's entire income.

Cash payments towards credit-card dues used for trading purchases were treated as connected to business transactions, not wholly unexplained money. As the cards were not shown to have funded capital acquisitions or personal expenditure, taxing the full payments would tax gross receipts rather than real income. Under the presumptive-taxation scheme, the disclosed profit rate was accepted as fairly representing business profitability in the absence of contrary Revenue material. Accordingly, only the profit element in the cash payments could be added, while the balance was to be deleted.

Reasonable cause under the Income-tax Act protected an educational trust from penalty for non-compliance with notices issued during the COVID-19 pandemic. The disruption, the trust's bona fide belief regarding exemption, subsequent participation in assessment proceedings, and remand of the quantum proceedings supported its explanation. In the absence of independent material showing deliberate or wilful disregard, the default was treated as technical or venial. Although penalty proceedings are independent of assessment proceedings, reasonable cause rendered the penalty unsustainable and required its deletion.

Unexplained investment under Section 69 was deleted where confirmations, tax returns, financial statements, ledger accounts, bank records and fund-flow evidence established the source and movement of funds, including direct banking-channel payments to the property seller. Once this initial burden was discharged, contrary material was required to treat the investment as unexplained. Cash deposits under Section 69A were treated as explained to the extent supported by disclosed professional, interest and rental income, since disclosed cash cannot ordinarily be taxed again merely on bank deposit. However, insufficient records supported the opening cash balance, so only 50% of that balance remained taxable as unexplained money.

Share-sale proceeds and long-term capital gains cannot be treated as unexplained cash credits merely on general penny-stock investigation material where the taxpayer substantiates the transactions through share application records, broker notes, banking channels, demat statements, stock-exchange sale records and securities transaction tax payment. Cogent evidence must connect the taxpayer to price manipulation, sham transactions or accommodation entries; absent such evidence, the addition is deleted. Estimated commission expenditure for an alleged accommodation entry also cannot be added as unexplained expenditure when it is only consequential to the rejected cash-credit allegation and lacks independent evidence of expenditure.

A notice under Section 143(2) in reassessment proceedings following Section 148 is required only where the Assessing Officer considers verification of income, loss or tax liability necessary or expedient. A return filed in response to reopening is treated as a Section 139 return, and participation in reassessment may invoke the deemed-service rule under Section 292BB. A business-loss disallowance may be examined where it directly relates to the income forming the recorded basis for reopening; the factual validity of the write-off remains examinable through the statutory appellate process.

Following a search initiated after 1 April 2021, a timely pending original assessment may be completed under Section 143(3); reassessment under Section 148 is not mandatory. The post-2021 framework does not expressly bar scrutiny assessment after a Section 132 search, and Section 132(8) recognises Section 143(3) assessment concerning seized material. Explanation 2 to Section 148 applies where a completed assessment or intimation is followed by search, or the period for regular processing or scrutiny has expired; it does not replace an original assessment that remains pending within limitation. Timely issuance of notice under Section 143(2) and completion of assessment support validity.

Compounding fee must be recomputed under the CBDT Guidelines dated 16.05.2008 because their applicability had already been conclusively determined between the parties and affirmed in appeal. A direction to calculate and communicate the fee concerned quantification only and could not reopen the settled governing framework. The power to issue compounding instructions cannot displace a final inter partes judicial determination. The revised 2024 Guidelines were also inapplicable because the compounding application had not been rejected for a curable defect contemplated by those Guidelines. The recomputation must credit the amount already paid by the assessee.

Section 194A(3)(v) exempts a co-operative bank, as a co-operative society, from deducting tax at source on interest paid to non-member co-operative societies. The provision's exemption for payments by one co-operative society to another does not exclude co-operative banks, and the CBDT clarification confirms its application to interest on time deposits. Recipient societies' deductions under Section 80P(2)(d) concern their assessments and do not alter the payer's independent TDS obligation. As no TDS obligation arises on such payments, the bank cannot be treated as an assessee in default or charged consequential interest.