Penalty proceedings under Section 270A require a notice under Section 274 to identify the precise charge, namely under-reporting or the applicable misreporting limb. Notices referring generally to "under-reporting/misreporting" without specifying the statutory basis fail to clearly inform the assessee of the allegation and are not in accordance with law. Such defective notices invalidate the consequential penalty proceedings, resulting in deletion of penalties for both assessment years.

Reassessment for Assessment Year 2015-16 was time-barred because the first proviso to Section 149(1) preserves the pre-amendment limitation restriction for years up to Assessment Year 2021-22. The applicable six-year period expired on 31 March 2022. The fifth and sixth provisos, excluding time allowed or extended for a response under Section 148A(b), operate within the amended three-year and ten-year framework and do not enlarge the first-proviso restriction. As no extension to respond under Section 148A(b) was sought, the subsequent Section 148 notice was beyond limitation. A non-speaking special leave petition dismissal does not confirm lower-court reasoning or trigger merger.

Rejection of liquor-trading books is justified where proper accounts, stock registers, sale bills and supporting vouchers are not maintained, and reported net profit is below the range accepted in comparable businesses. Profit may therefore be estimated at 3% of stock put to use. Advertisement-display charges received from liquor companies for use of business-premises space constitute business receipts separate from core trading turnover. Where estimated trading profit is computed only on stock put to use and does not include those receipts, separate addition of the display charges as business income is justified. The estimated trading profit and separate treatment of display-charge receipts remain sustained.

Tax-deduction liability for leave travel concession reimbursements involving foreign travel does not arise automatically under Section 201(1). The Revenue must examine whether beneficiary employees have paid the relevant tax. Where a subsisting judicial direction prevented treatment of the reimbursement as income for tax-deduction purposes and placed any eventual tax liability on employees, compliance with that direction cannot create deductor default. On materially identical facts, consistency with a coordinate-Bench approach also supports deletion of demands under Sections 201(1) and 201(1A). A penalty under Section 271C founded solely on the quashed tax-deduction default has no independent basis and must also be deleted.

Bad-debt deduction for written-off commodity-trading receivables is allowable where the receivables arose from trading transactions, were previously offered as income, and were written off in the books; the possibility of later recovery does not defeat the claim, and any recovery is taxable when received. Computation of deduction for windmill units requires factual examination of whether head-office expenditure and depreciation on common assets are attributable to those units. The composition of such expenses, outsourced operational arrangements, and the use of common assets must be examined before allocating expenditure and determining eligible windmill profits.

The enhanced tax rate under Section 115BBE, effective from 1 April 2017 without express retrospective operation, does not apply to unexplained income surrendered for Financial Year 2016-17. Such income, including surrendered cash and gold treated as unexplained income, remains taxable at the pre-amendment rate, with applicable surcharge and cess. A bank cash deposit may be telescoped against cash surrendered during survey only after verification that the surrendered cash or recorded cash balance remained available and was not otherwise used. Credit should be allowed to the extent of available cash, preventing duplication of additions.

Section 80P deduction does not extend to interest on income-tax refunds, whose proximate source is statutory compensation for excess tax retained, or to interest on deposits with commercial banks, which is neither business income from the specified activity nor investment income from another co-operative society. Interest and dividends from investments with co-operative societies may qualify if verification establishes the investee entities' co-operative status and the statutory conditions. Excess contributions to an approved gratuity fund beyond the prescribed annual limit are not deductible. Interest paid for delayed deposit of tax deducted at source is not allowable as business expenditure. A challenge solely to initiation of penalty proceedings is premature and must be addressed in the separate penalty proceedings.

Penalty for failure to obtain a tax audit was not sustainable where GST was accounted for separately as a liability under the exclusive method and the taxpayer reasonably believed it was excluded from turnover for the tax-audit threshold. ICAI guidance recognises that no turnover adjustment is needed where tax is included in the sale price. Differing views on GST inclusion, coupled with the absence of deliberate, knowing, mala fide or contumacious non-compliance, established reasonable cause. The penalty was therefore directed to be deleted.

Depreciation on goodwill arising from amalgamation remains allowable where it was admitted in the amalgamation year, entered the intangible-asset block, and the opening written-down value became final without any change in facts, law, valuation, or block composition. Depreciation is mandatory once the statutory conditions are met, and the settled basis of the opening written-down value cannot be reopened in a later year. Vendor compliance expenses deducted from export proceeds are allowable where contemporaneous records establish their direct nexus with export sales. Deductions for retail-support activities, including promotional and display arrangements, need not be disallowed merely because separate invoices are unavailable when the amounts are supported by customer-program and remittance records.

Faceless reassessment jurisdiction under Sections 147 and 144B extended to the National Faceless Assessment Centre before Notification No. 18/2022 where binding CBDT directions under Section 119 required it to complete reassessments, subject to specified exclusions. The later Section 151A notification did not invalidate reassessments completed under the earlier faceless-assessment framework. Additions for cash payments and rent income made in an ex parte assessment required fresh appellate adjudication because the assessee's continuing mental illness prevented effective participation. The first appellate authority must provide three effective opportunities to furnish supporting material before deciding those additions on merits.

Bank deposits arising from xerox and fabric-trading transactions cannot be assessed in full as unexplained cash credits where the related withdrawals, transaction details and stock particulars indicate genuine business activity. Although handmade supporting bills were not accepted as reliable, taxation must be confined to the income element embedded in alleged bogus cash receipts rather than the gross deposits. Applying the presumptive-taxation standard, income is estimated at 8% of the cash receipts deposited in the bank account.

Domestic companies with turnover below the prescribed threshold are taxable at the 25% rate under the applicable Finance Act. Eligibility depends on the statutory conditions, not on an incorrect reference to section 115BA in the return. A mistaken provision cited while claiming the lower rate does not permit taxation at 30% where the Finance Act independently prescribes the 25% rate. The applicable rate must therefore be determined from the company's eligibility under the Finance Act.

Reassessment cannot be used to recharacterise property-sale proceeds already assessed as long-term capital gains as business income solely by revisiting the same assessment record. Where the original scrutiny considered the sale transaction and the property had consistently been shown as a fixed asset, an audit-driven reopening requires fresh tangible material establishing income escapement. A different view of the same facts is an impermissible change of opinion, rendering the reopening and consequential reassessment invalid.

Interest disallowances relating to unsecured loans required fresh adjudication because substantially similar issues for the preceding assessment year had been restored for de novo consideration. The outcome for that preceding year was material to determination for the relevant year. No view was taken on the merits, and the appellate authority was required to reconsider the matter after providing adequate hearing opportunity, together with the connected preceding-year proceedings.

Jurisdictional objections to reassessment, including challenges to notice, statutory procedure and disposal of objections, must be adjudicated before addressing additions on merits. Section 250(6) requires an appellate order to identify points for determination, decide them and provide reasons. The discretionary power to set aside a best-judgment assessment for fresh assessment does not remove this duty. The validity and effect of filings made through a deceased assessee's electronic account require record-based examination without a stated conclusion. A reasoned speaking order must determine the legal and jurisdictional grounds before any remand of merits.

Dividend distribution tax under Section 115-O was contested on whether the India-Netherlands tax treaty rate could apply instead. Pending Supreme Court proceedings against the jurisdictional High Court ruling on the same issue, together with directions to consider staying comparable matters, required judicial discipline and precluded adjudication at that stage. The issue was restored for fresh adjudication after the Supreme Court decision.

Transferable development rights received in exchange for surrendered land constitute capital assets acquired at an ascertainable cost: the cost attributable to the land surrendered. Their subsequent sale is therefore taxable under capital gains provisions, with that attributable land cost deductible in computing the gain; the rule for self-generated assets with no conceivable acquisition cost does not apply. Verification of a refund claim did not restrict scrutiny of the claimed exempt receipt where no limited-scrutiny restriction was stated. Acceptance of exemption in another taxpayer's assessment does not compel identical treatment, as an erroneous or unexamined assessment does not bind tax authorities or create estoppel against correct statutory application.

Ind AS accounting recognition does not independently determine taxable income where the Income-tax Act or ICDS prescribes a different computation. Notional income from unwinding an interest-free security deposit, royalty already taxed as upfront consideration, EPCG duty benefits connected with assets, and borrowing-cost differences under ICDS IX were not taxable or disallowable merely because of Ind AS presentation; the related additions were deleted. Absence of Form 3CL could not defeat deduction for an approved in-house research and development facility where issuance lay with the prescribed authority. TDR cost and set-off, leave-entitlement provision, and gift expenditure required verification of prior records, computation treatment, business purpose and evidence, and were restored for fresh determination.

Reassessment based on an audit objection requires objective material showing that identified disclosed credits are non-genuine; suspicion arising from alleged non-verification of sundry creditors is insufficient. Cash payments for purchases of raw hides and skins are permitted under section 40A(3) read with Rule 6DD(e)(ii). Where books record sellers' or creditors' names and relevant mandi details, and no material casts doubt on those particulars or the sellers' existence, failure to provide PAN or addresses cannot support an adverse inference absent a legal requirement to maintain them. Reopening on these facts lacks jurisdiction and amounts to an impermissible fishing enquiry.

Reassessment based on seized third-party material requires a live and direct nexus with the taxpayer's transaction. An inquiry-register entry recorded before the registered land purchase described land available for sale, covered additional survey numbers and a larger area, named an unconnected person, and did not refer to the taxpayer or co-purchasers. The broker's admissions further undermined any assumption that every entry reflected an actual financial transaction. Mere overlap in some survey numbers could not establish undisclosed on-money payment, rendering the reassessment notice unsustainable.