Deduction for interest earned by a co-operative housing society on deposits with co-operative banks falls within section 80P(2)(d) where the society is a co-operative society and the investment is made with another co-operative society. Co-operative banks registered under applicable co-operative societies law meet the recipient condition. Section 80P(4) restricts a co-operative bank's own eligibility for section 80P deduction, but does not bar another co-operative society from claiming deduction on interest received from such a bank. Where non-jurisdictional High Court views differ, the interpretation favourable to the assessee applies to this beneficial deduction provision.

Approval under section 10(23C)(vi) is available where an institution exists solely for educational purposes and not for profit. Incidental surplus from educational activities does not demonstrate a profit motive when retained and applied to educational infrastructure and facilities. Construction on trustees' land does not itself establish diversion of funds unless material shows siphoning, private appropriation, or pecuniary benefit, particularly where the infrastructure serves educational activities. The State-law registration objection ceased after registration was obtained from the competent Devsthan authority. As no non-educational activity, surplus distribution, income diversion, or private benefit was established, approval was required to be granted.

Excess tax deducted at source is refundable where a return filed in response to a notice under section 148 is accepted in reassessment and nil taxable income is determined. Section 237 creates a substantive refund entitlement when tax paid exceeds the tax properly chargeable, and no statutory bar denies that entitlement solely because the return was furnished under section 148 rather than section 139. The refund is consequential to the reassessment, not an independent claim beyond its scope. Retaining TDS after no tax liability remains would also conflict with Article 265 of the Constitution. Statutory interest applies consequentially.

A reassessment notice under section 148 is issued when digitally authenticated and communicated, not merely when it bears an earlier date. Where the electronic record showed that a notice dated 31.03.2021 was digitally issued by email on 01.04.2021, it fell outside the applicable limitation period. Applying jurisdictional High Court authority on materially identical facts, the notice was time-barred and invalid, resulting in quashing of the reassessment proceedings.

Ex-gratia retrenchment compensation received by BSNL employees under the Voluntary Retirement Scheme, 2019 qualifies for exemption under Section 10(10B) of the Income-tax Act, 1961. Entitlement to the exemption is not defeated merely because the employee offered the amount to tax based on Form 16, omitted the claim in the original return, or had a rectification claim rejected. Appellate powers may be exercised to allow a legally valid exemption claim not made before the Assessing Officer.

Foreign Tax Credit should not be denied solely because Form No. 67 was furnished after the return-filing due date under Rule 128(9). Although the rule required timely filing for the relevant assessment year, it did not prescribe denial of credit as the consequence of delay. The later extension of the filing period and treatment of the requirement as directory support allowing substantive credit where foreign income was offered to tax in India and Form No. 67 with foreign-tax supporting documents was available before processing. The Foreign Tax Credit claim must therefore be examined on merits after accepting the form and related documents, while providing a reasonable hearing opportunity.

Commission expenditure supported by PAN, GST, TDS, tax-return and banking records cannot be treated as non-genuine solely because the recipient does not respond to a departmental notice, absent evidence that the recipient is fictitious, documents are false, or funds returned to the payer. Loan credits are not unexplained where lender identity, prima facie creditworthiness and transaction genuineness are established through tax, confirmation and bank records, unless rebutted by cogent evidence. Small lorry-driver and cleaner payments may qualify as business expenditure where commercially incidental to operations and individual vouchers are impracticable; disallowance requires evidence of bogus, inflated, personal or non-business payments.

Assessment issued and completed in the name of an amalgamating bank after its merger is jurisdictionally invalid where the Assessing Officer knew that the bank had ceased to exist. Such invalidity is not a procedural defect curable under Section 292B, and the successor entity's participation cannot validate proceedings against a non-existent entity. The assessment is therefore void from inception and liable to be quashed.

Section 56(2)(x) applies only where an assessee receives land, a building, or an independently identifiable immovable-property right during the relevant year. A supplementary agreement modifying building plans under a pre-existing property arrangement does not trigger the provision where it neither transfers fresh immovable property nor creates an additional independent proprietary right. Absence of additional consideration supported the conclusion that no qualifying receipt occurred. Stamp duty valuation is relevant only after receipt of qualifying immovable property is established and cannot independently bring the transaction within section 56(2)(x). Accordingly, the addition based solely on the supplementary agreement's stamp duty valuation was deleted.

Section 68 requires identification of a specific unexplained credit; reconciled capital movements and cash deposits recorded in audited accounts from disclosed professional receipts cannot be treated as unexplained without identified defects or cash deficits. Property received on partition of a Hindu undivided family takes the previous owner's cost and holding period, allowing indexed cost computation. Resulting eligible long-term capital loss may be set off against qualifying long-term capital gains and carried forward subject to statutory restrictions. Registered sale consideration received through banking channels, supported by the conveyance and tax-deduction trail and accepted for capital-gains computation, should not also be assessed as an unexplained credit absent evidence of a sham or recycled funds.

Sponsorship receipts from a women's marathon integrally connected with charitable objects of health, fitness, awareness and empowerment do not constitute trade, commerce or business merely because sponsors obtain promotional benefits or the event generates substantial receipts or surplus. Commerciality depends on the activity's intrinsic nature, purpose and manner, not the sponsors' accounting treatment or receipt quantum. The proviso to section 2(15) and section 13(8) therefore do not apply where no independent commercial undertaking or distinct commercial services exist. Furnishing Form 10BB instead of Form 10B is a curable procedural defect where accounts were audited before filing, valid registration existed, and Form 10B was submitted during assessment; it does not defeat exemption under section 11.

Unexplained-credit, unexplained-expenditure and unexplained-money additions cannot rest on general investigation inputs or presumptions where transactions are supported by lender confirmations, audited financial statements, tax records, bank statements, ledgers, TDS records and repayment evidence. Identifiable corporate lenders with disclosed financial capacity and business operations support the genuineness of banking-channel loans. Interest on established genuine borrowings is not unexplained expenditure. Presumed accommodation-entry commission requires evidence of cash outflow or payment. Alleged bogus purchases require material contradicting invoices, transport records, e-way bills, ledgers and banking payments. Repayment of documented opening loan balances through banking channels does not itself establish ownership of unexplained money.

Deemed rental value of unsold flats held as stock-in-trade was not assessable for Assessment Year 2017-18. Section 23(5), which expressly provides for taxation of deemed rental income from unsold stock-in-trade, took effect from Assessment Year 2018-19 and did not apply retrospectively. Where High Court views conflicted, the interpretation favourable to the assessee applied. Accordingly, the notional rental-income addition for unsold flats retained as stock-in-trade for Assessment Year 2017-18 was deleted.

Reassessment notices issued more than three years after the end of the relevant assessment year require prior sanction from the higher authorities expressly specified in section 151(ii). Approval by a Principal Commissioner, rather than the prescribed Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General, fails this jurisdictional condition. Consequently, the notice under section 148 and all consequential reassessment proceedings are void from inception. A delay caused by an accountant's absence due to a family medical emergency may be condoned where supported by an affidavit and shown to be unintentional and beyond the assessee's control.

Section 80P(2)(d) permits a co-operative housing society to claim deduction for interest earned from investments with co-operative banks. The term "investment" is not limited to fixed deposits and includes funds kept in savings accounts. Interest from savings accounts maintained with co-operative banks therefore qualifies for deduction, as such banks are treated as co-operative societies for this purpose. The deduction applies to interest income earned from both deposits and savings accounts with co-operative banks.

Property-purchase additions treated as unexplained money were unsustainable where agreements to sell, cash-flow statements corroborated by bank records, family income-tax returns, loan confirmations, sale deeds, and booking and payment records established the sources and legitimacy of the transactions. The documented evidence sufficiently explained the funds used to acquire the two properties, requiring deletion of the addition.

Interest income earned by a co-operative housing society from deposits with co-operative banks qualifies for deduction under Section 80P(2)(d). The provision permits deduction of interest or dividend derived by a co-operative society from investments with another co-operative society, and co-operative banks are treated as co-operative societies for this purpose. The exclusion in Section 80P(4), applicable to co-operative banks, does not bar an assessee co-operative society from claiming deduction on interest received from such banks.

Unexplained expenditure under section 69C requires failure to explain the source of expenditure or an explanation of that source that is unsatisfactory. Payments made through bearer cheques from the assessee's recorded bank accounts cannot be added merely because they exceed the purchases and expenses claimed, unless the source of those payments is found unexplained. An inability to establish the purpose or destination of payments does not satisfy the statutory requirement concerning their source. The addition was therefore unsustainable and liable to be deleted.

Rule 68B's 2019 extension of the period for sale of attached immovable property applies to recovery claims still within the earlier limitation period but cannot revive claims already time-barred. Recovery-sale proceedings for the earlier assessment years were therefore barred, while those for later years remained timely because the amended period applied before expiry. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial; consequently, the Supreme Court's COVID-19 limitation exclusion applied. For unappealed demands, Rule 68B finality arises only after expiry of the demand-payment and ordinary appeal periods, preserving the later recovery proceedings and preventing release of the attachment.

A writ challenge to a Tribunal recall order does not remain maintainable once the Tribunal passes a final order pursuant to that recall. The recall order merges into, and no longer exists independently from, the final order. Where the final order is separately challenged through the statutory tax appeal remedy, the antecedent recall order cannot be challenged independently by writ petition. The challenge against the assessee therefore failed on maintainability.