Tax deducted at source and remitted to the Government Treasury cannot continue as recoverable principal liability once relevant challans are verified and correlated with the corresponding transactions. Verification must confirm the correct tax amount, deduction date, deposit date and linkage between challans and payments. Payment of principal tax does not remove statutory interest for delayed remittance; interest remains chargeable only for the period from deduction/default until the actual date of deposit. Following verification, the corresponding principal demand must be deleted, while interest is confined to the period of delay.

Ad hoc disallowances of labour and repair expenses cannot rest solely on year-on-year expenditure comparisons without verifying supporting records or identifying bogus or inflated claims. The labour-charge and repair-expense claims require examination of ledgers, invoices and other evidence. Bad-debt deductibility requires factual verification of the receivable's origin, outstanding balance, adjustments, debtor acknowledgments, liquidation status and actual write-off. Unrefunded business-related input tax credit is not automatically non-deductible merely because it was rejected or not refunded under GST; its real nature, irrecoverability and connection with the business must be examined. Ultimate allowability of all claims remains subject to evidence-based determination.

Revisionary jurisdiction under section 263 is not attracted merely because a further or more extensive enquiry into a section 80JJAA deduction may be considered desirable. Where the Assessing Officer has examined the deduction through notices, a proposed disallowance, Form 10DA, employee-wise information, salary details and statutory-contribution records, the assessment reflects a conscious enquiry. Questions over client agreements, operational supervision, salary reimbursements and staffing arrangements concern the adequacy or manner of enquiry, rather than absence of enquiry. Deployment of employees at client premises, client supervision, or salary-cost reimbursement does not by itself displace the employer-employee relationship or additional employee cost for section 80JJAA purposes.

Cash deposits require a satisfactory explanation of their nature and source to avoid treatment as unexplained money. A claim that deposits originated from a partnership firm is not substantiated where the firm's ledger records the underlying sale after the stated cash receipt. Tax on unexplained-money additions remains subject to the rate applicable for the relevant assessment year. An amendment enhancing the tax rate applies prospectively from its stated operative assessment year and does not govern earlier years; the pre-amendment rate therefore applies to the relevant addition.

Section 68 addition is unsustainable where ledger records and supporting material show no fresh loan or unexplained credit during the relevant year, and the entry concerns interest on loans obtained in earlier years. Deemed dividend treatment does not extend to reciprocal, interest-bearing commercial dealings conducted through a current account. Repayments of prior advances and payments made on behalf of related entities do not become loans or advances merely because funds move between them. Strict construction of the deeming provision excludes such mutual commercial transactions, supporting deletion of both additions.

Live broadcasting licence fees were treated as outside royalty taxation under Article 13(3) of the India-UK tax treaty because a one-time live match feed neither confers an enduring benefit nor constitutes a scientific work or copyrighted work. The contractually agreed 95:5 allocation between live and non-live broadcasting rights remained undisturbed, absent material showing it was unjustified; consideration for non-live rights had already been offered to tax. Release fees paid to permit English players' participation in the IPL were also outside Article 18(2), as they were paid for consent and did not arise from the players' personal activities.

WhatsApp chats recovered from a third party's mobile phone cannot, without independent corroboration, sustain an addition for unexplained investment against another person. The presumption under Section 132(4A) applies only to the person from whom material is found and does not bind a third party. Electronic chats require proof of authenticity through the prescribed certificate, and compliance with requirements for extraction of electronic evidence must be demonstrated. In the absence of corroborative evidence establishing the alleged investment and valid authentication of the chats, the addition is liable to be deleted.

Sanction under Section 151 for reassessment must reflect meaningful satisfaction based on relevant facts, records and applicable law. Omission of an earlier assessment under Section 143(3) from the recorded reasons and sanction proforma, a bare endorsement that the matter was fit for notice under Section 148, no reference to supporting material, and an undated approval indicate mechanical sanction without application of mind. Such invalid approval vitiates the notice under Section 148, the assumption of jurisdiction under Section 147, and the consequential reassessment.

Reassessment notices issued after expiry of three years from the end of the relevant assessment year require approval from the competent authority under Section 151. For assessment year 2019-20, the extended limitation provision applied, making the Principal Chief Commissioner the competent sanctioning authority. Approval granted instead by the Principal Commissioner was invalid and did not confer jurisdiction to initiate reassessment. Consequently, the reassessment notice and consequential assessment were quashed in favour of the assessee.

Commission paid to non-resident agents for procuring export orders is not chargeable to tax in India where the agents render all services outside India and have no permanent establishment or business operations in India. The connection between the commission and export orders executed by an Indian payer does not, by itself, cause the income to accrue or arise in India. Since tax deduction at source applies only to payments chargeable to tax in India, no withholding obligation arose on the foreign-agent commission, and the related disallowance was deleted.

Foreign Tax Credit cannot be denied solely because Form 67 was furnished after the prescribed time where foreign income was offered to tax in India, taxes were paid abroad, and eligibility for the credit is undisputed. Delay in filing Form 67 does not prejudice the taxpayer's substantive entitlement to credit for foreign taxes. Foreign Tax Credit must therefore be granted, with the necessary rectification carried out.

Timely filing of Form 10-IE for opting into the new tax regime under section 115BAC was treated as sufficient despite a delayed return of income. The timing requirements for Form 10-IE and the return were regarded as directory rather than mandatory, and delay in filing either may be condoned. Consequently, delayed filing of the return after the due date under section 139(1) did not invalidate the taxpayer's option for taxation under the new tax regime.

Recorded reasons for reopening must be furnished to the assessee on request so that objections can be raised during reassessment proceedings. Where assessment records and factual findings show no evidence that the reasons were communicated or supplied, the reassessment lacks validity and is liable to be quashed. The failure to provide recorded reasons therefore invalidates the reassessment in favour of the assessee.

Additional legal grounds challenging extended search-assessment jurisdiction are admissible where they are purely legal, go to the root of assessment validity, require no fresh facts, and arise from the assessment record. For years beyond the ordinary six-year period, the fourth proviso to Section 153A(1) permits action only when material reveals escaped income represented by a qualifying asset and meeting the prescribed threshold. Additions based solely on alleged on-money receipts, without identifying escaped income represented by such an asset, cannot support extended-period notices or assessments. The extended-period assessments were therefore void from inception, and all relevant assessments were quashed.

Agricultural land is excluded from capital-gains tax only when it is not a capital asset. Land acquired from an urban housing authority, without evidence of agricultural use since 1981 and situated near a railway station within municipal proximity, was treated as a capital asset; the resulting long-term capital gain was taxable in Assessment Year 2013-14. Where common funds are maintained and own funds exceed advances, advances are presumed to have been made from own funds rather than interest-bearing borrowings. Accordingly, no proportionate interest disallowance was warranted, while the capital-gains addition remained sustainable.

Reopening under Section 148 is impermissible where it merely reflects a genuine change of opinion on material examined in the original assessment. A licensing-related ground not considered during the original assessment does not constitute such a change of opinion, so reassessment may proceed. Advances made through negotiable instruments fall outside the licensing requirement under the Rajasthan Money Lending Act, 1963, but the exemption requires specific supporting particulars and proof that the material was previously supplied to the Assessing Officer. The reopening notice and rejection of objections were sustained, subject to verification of the instrument particulars by the Assessing Officer.

Reassessment limitation for AY 2013-14 expired on 31 March 2020. Extensions applied only where the original limitation date fell within their expressly specified periods; the later extension from 31 March 2021 to 30 April 2021 did not cover an original expiry on 31 March 2020. Although signed on 31 March 2021, the notice was issued on 1 April 2021 and was time-barred, rendering the consequential assessment orders legally invalid. Participation in reassessment proceedings does not cure a notice issued beyond statutory limitation, because the deeming rule concerns defective service rather than delayed issuance.

Section 276CC's proviso excludes prosecution for delayed return filing where tax payable on total income determined on regular assessment, after credit for advance tax and tax deducted at source, does not exceed the prescribed threshold. Where reassessment additions are deleted in appellate proceedings and tax deducted at source exceeds the resulting tax liability, no tax remains payable by the assessee. In those circumstances, prosecution is barred, and its continuation amounts to an abuse of process of law.

Corporate guarantee settlement liability became deductible in Assessment Year 1998-99 because the parties had agreed the full and final liability during the relevant previous year. Board approval and correspondence supported crystallisation of the obligation in that period. Subsequent filing of consent terms and payment in 1999 merely implemented the liability already determined and did not defer deductibility. The factual finding on crystallisation of liability remained undisturbed, resulting in deductibility for the relevant assessment year.

Faceless assessment procedure requires necessary enquiries, verification and collection of relevant information before a show-cause notice, followed by specific queries, proper consideration of replies and a meaningful personal hearing. Additions cannot rest on grounds not raised in the show-cause notice or on information never sought from the assessee. A hearing opportunity limited to a few hours, without a fresh opportunity after a failed video-conference link, denies effective participation. Breach of these requirements renders the assessment, consequential demand and penalty notices unsustainable, requiring proceedings to restart from the show-cause-notice stage.