Delayed electronic filing of Form No. 10-IE due to uncontroverted portal difficulties does not defeat an assessee's option for the concessional tax regime under section 115BAC where the option was unequivocally exercised. Filing the prescribed form with a revised return shortly after the extended due date constituted substantive compliance because the form was available with the Department and there was no complete non-compliance, abandonment, deliberate withholding, or misuse. The form should be considered and tax liability recomputed under the opted concessional regime.

Timely filing of the return is a mandatory condition for claiming Chapter VI-A deductions, including deduction for co-operative society income, where the return must be furnished by the due date. Processing of a belated return may disallow such deduction. A rectification application cannot restore the deduction because the disallowance resulting from late filing does not constitute a mistake apparent from the record. Consequently, the deduction remains unavailable and rejection of rectification is legally valid.

Rental income should not be increased through an estimated market rent drawn from an incomparable property in another city when no credible local evidence supports a higher rent and the disclosed rent exceeds standard rent. Salary paid to a family member is allowable where sustained business and banking functions establish genuine services, business results support the expenditure, and the recipient offers the salary to tax. Interest on unsecured loans may be commercially expedient despite a higher stated rate than secured borrowings, considering the effective cost of bank finance, flexibility and repayment terms. Unsupported rental estimates and unjustified salary or interest disallowances cannot be sustained where transactions are reasonable and genuine.

Section 167B does not apply to a public charitable society merely because its members' income shares are unspecified. The provision applies where members of an association of persons or body of individuals have indeterminate or unknown shares, whereas a public charitable body serves the public at large and its members have no entitlement to its income. Its income is therefore taxable at the normal rate applicable to an association of persons, rather than at the maximum marginal rate.

Section 87A rebate applied to tax computed on total income for the relevant period, with no express exclusion for tax on short-term capital gains chargeable at special rates under section 111A. The later restriction introduced by the Finance Act, 2025 operated prospectively and did not affect the relevant claim. Automated denial of the rebate could not displace the statutory entitlement. Rebate under section 87A was therefore available against tax payable on eligible short-term capital gains under section 111A.

Banking tax computation addresses arm's-length remuneration, provisions, securities valuation, income recognition and statutory deductions. Technical and IT-enabled services supplied to associated enterprises require value-based arm's-length remuneration; where reliable contemporaneous comparables are unavailable, a 10% cost mark-up is reasonable. Actuarially valued pension and employee obligations arising from past service are accrued liabilities, but leave encashment follows the actual-payment requirement. Banking securities may be consistently valued at cost or market value, whichever is lower, and interest on non-performing assets is taxable only on realisation under the real-income principle. Foreign-branch income remains taxable in India with treaty relief. Deductions for standard-asset provisions, bad debts and eligible business income depend on statutory conditions and verified computations.

Penalty proceedings under section 271D, where no assessment or related order exists during which they were initiated, fall under the six-month limb of section 275(1)(c). The relevant financial-year limb does not apply in that situation. The show-cause notice issued under section 274 read with section 271D constituted initiation of penalty action at the latest. As the penalty order was issued after expiry of six months from the end of that month, it was time-barred, quashed, and the sustained penalty was deleted.

Interest awarded under a foreign arbitral award becomes part of a judgment debt once the award is declared enforceable under section 49 of the Arbitration Act and treated as a court decree. The interest component then loses its separate character as interest. Because the amount does not arise from money borrowed or debt incurred, it falls outside the Income-tax Act definition of interest. The treaty provision governing interest income is therefore inapplicable, and the decretal amount representing arbitral interest is not taxable in India.

TNMM benchmarking for a limited-risk distributor of licensed content should assess comparability through functions, assets, risks, contractual terms and reliable financial data; product differences alone do not render software or hardware distributors unsuitable comparables. Rejection of the examined comparables solely because they were outside the film or entertainment industry lacked identified material functional or risk differences. An Other Method revenue split requires comparable uncontrolled transactions, reliable market evidence, or an objective economic basis for allocation. Assigned FAR weightages cannot quantify economic value merely by identifying functions and risks. TNMM was applied for arm's-length-price recomputation, deleting the consequential transfer-pricing adjustment.

Section 92CA(1) confines a Transfer Pricing Officer's reference to determining the arm's length price of a specified international transaction under section 92C. It does not extend to determining whether a permanent establishment exists under Article 5 of the India-Singapore tax treaty, or whether and how business profits are taxable and attributable under Article 7; those issues remain for the Assessing Officer. Where remand required the Assessing Officer to re-examine permanent establishment after cross-examination and consideration of relevant material, a reference without an identified international transaction exceeded transfer-pricing jurisdiction. An assessment based solely on such findings, without independent verification by the Assessing Officer, was unsustainable.

Section 200A acquired express power to compute and demand late fee under Section 234E only from 1 June 2015, and that amendment operates prospectively. Consequently, an intimation under Section 200A cannot validly levy Section 234E late fee for delayed quarterly TDS statements relating to periods before that date. Where High Court decisions conflict on the issue, the interpretation favourable to the assessee applies. Late fee imposed for TDS statements pertaining to financial year 2012-13 was therefore not chargeable and must be deleted.

For property acquired through allotment, section 56(2)(x) requires stamp duty value to be determined as on the agreement or allotment date, rather than the conveyance-registration date, where consideration was paid through banking channels before registration. Formation records, trustee confirmation, a pre-existing bank account, developer confirmation and banking-channel payment supported the trust's existence and the booking advance before PAN incorporation. Because the stamp duty value on the relevant allotment date was lower than the purchase consideration, no addition for alleged excess stamp duty value was sustainable.

Section 80G(5B) treats an institution or fund whose religious expenditure does not exceed five per cent of total income as eligible for Section 80G. Approval under Section 80G(5) cannot be denied merely because a trust has religious objects where its objects are substantially charitable and serve the general public, without first determining whether religious expenditure exceeds that threshold. The restriction concerning benefits for a particular religious community or caste under Section 13(1)(b) is relevant to exemption under Section 11 rather than registration under Section 12A. The application requires verification of the applicable statutory conditions.

Section 80-IB(10) deduction requires a qualifying housing project to satisfy the minimum plot-area condition and prescribed residential-unit built-up area. Excluding land initially earmarked for the project and using it for a personal residence exceeding the permitted unit area removes that land from the qualifying project. Where the remaining project area falls below the statutory minimum, the deduction is unavailable for the relevant assessment years.

Assessment completed without considering the assessee's response to a show-cause notice, despite a prior direction to consider it, breaches the principles of natural justice. The limitation period does not excuse non-compliance with that direction or deny effective consideration of the response. Such an assessment is invalid and requires fresh assessment proceedings after due consideration of the reply.

The clean slate principle applicable to a corporate debtor acquired as a going concern in liquidation extinguishes past liabilities and investigations, preventing their imposition on the purchaser. Reassessment for alleged cessation of interest liability cannot rest on conjecture that interest was claimed as a deduction where records show no such claim after the account became a non-performing asset. The same alleged cessation cannot be repeatedly subjected to reassessment for earlier and later assessment years. Failure to address the clean slate defence and relevant statutory records rendered the reassessment notice and order invalid and liable to be quashed.

Reasoned Tribunal adjudication requires meaningful consideration of the parties' contentions and the issues arising from assessments. A common order disposing of seven appeals was procedurally irregular because it also covered separate sets of appeals heard and pronounced on different dates. The absence of reasons and apparent undue haste rendered the order unsustainable, requiring fresh and independent adjudication by a different Bench, with all merits remaining open.

Revenue's proposal to drop reassessment proceedings against the purchasing company rendered the reassessment notice and all consequential proceedings unsustainable, notwithstanding its reserved right to proceed against the seller company. The reassessment notice and resulting proceedings against the purchasing company were quashed, as the stated withdrawal left no basis for their continuation in law thereafter.

Exchange of information under tax treaties is considered in relation to the one-year extension of the assessment limitation period where foreign tax information is sought. The key issues are the scope of the India-Swiss Confederation treaty, reliance on the India-Hong Kong treaty's information-exchange provision, and whether the information relates to the relevant fiscal year. These matters determine whether assessment for the relevant assessment year can proceed within the extended limitation period.

Reassessment against an amalgamating company cannot continue after its successor has been assessed for the same income and assessment year. Assessing identical share application money in the amalgamated successor's hands treats that successor as the person liable following amalgamation. Parallel proceedings against the predecessor, which has ceased to exist, would expose the same income to duplicate assessment and taxation. The reassessment notice and consequential proceedings against the amalgamating company were therefore quashed, with the issue resolved in the assessee's favour.