Unverifiable purchases arising from missing supplier confirmations, complete addresses and PAN details can justify rejection of books of account under Section 145(3), notwithstanding production of ledgers and a GST-based reconciliation of purchase and creditor balances. Profit estimation following book rejection must nevertheless remain reasonable and be supported by comparable industry data. Where the declared gross profit rate is materially below comparable rates, gross profit may be estimated at a fair rate rather than an excessive rate; the addition is consequently recomputed using a 4% gross profit rate on declared turnover.

Transactional Net Margin Method (TNMM) was identified as the most appropriate method for benchmarking an export transaction with an associated enterprise because it had been consistently accepted for the same transaction in earlier assessment years. No change in facts or law justified departure from that approach, and prior application of TNMM had resulted in no transfer-pricing adjustment. Consequently, a transfer-pricing adjustment determined under the Comparable Uncontrolled Price method could not be sustained.

Reassessment notices for assessment years commencing on or before 1 April 2021 remain subject to the limitation available under the pre-amendment regime under the first proviso to Section 149(1). For Assessment Year 2015-16, that preserved period expired on 31 March 2022, making a notice issued on 7 April 2022 time-barred; subsequent provisos cannot enlarge the preserved restriction. Sufficient cause for delayed appeals may arise where proceedings were initially filed before an incorrect territorial forum, communications were not received at an old address, and prompt action followed knowledge of the assessment.

Stay of recovery of disputed income-tax demand was extended where delay in disposal of the appeal was not attributable to the assessee, the relevant assessment year was covered by a pending Advance Pricing Agreement, and the assessee had furnished the required bank guarantee under the earlier stay condition. The continuing prima facie case, balance of convenience and relative hardship supported protection from recovery. The stay operates for 180 days or until disposal of the appeal or the assessee's acceptance of the Advance Pricing Agreement, whichever occurs first.

Recovery of outstanding tax demand pending appeal may be stayed where the taxpayer establishes a prima facie case and balance of convenience. Consistent use of the Transactional Net Margin Method in earlier accepted years, followed by a Comparable Uncontrolled Price Method adjustment without a demonstrated change in facts, supported interim protection. Applying the payment requirement under the second proviso to section 254 of the Income-tax Act, recovery was stayed upon payment of 20% of the outstanding demand. The remaining demand was stayed for 180 days or until disposal of the appeal, whichever occurred earlier.

Section 69 links an alleged unexplained investment to the financial year in which the investment is actually made, rather than the year in which title is perfected by registration. Bank-channel payments made in November 2017 fell in FY 2017-18; subsequent registration in FY 2018-19 did not shift the investment to that later year because Section 69 contains no deeming fiction to do so. Consequently, an addition for AY 2019-20 based on those payments was unsustainable and deleted.

Export incentives directly linked to export activity form part of the tested party's operating results under the Transactional Net Margin Method. They must therefore be included as operating income when computing the tested party's profit level indicator and arm's length margin. Excluding them solely because selected comparables do not receive similar incentives would distort the tested party's operating margin, particularly where incentives received by comparables are treated as operating income. The recomputation consequently includes export incentives in the tested party's operating income.

Rectification jurisdiction cannot be used to reconsider the factual basis of an earlier order. A miscellaneous application relying on dates relating to the proposal, approval and transmission of a transfer-pricing reference, rather than the date previously recorded as received by the Transfer Pricing Officer, sought review of the finding that the assessment was time-barred. Such reconsideration exceeds rectification jurisdiction; the miscellaneous application was therefore treated as an impermissible review and dismissed as devoid of merit.

Cancellation of charitable registration under Section 12AB(4) requires cogent material proving a specified violation, namely non-genuine activities or departure from charitable objects. Assessment-related verification issues, procedural deficiencies, unregistered lease documentation, incidental receipts, unsupported expenditure, family management without prohibited benefit, and recorded donations do not alone meet that threshold. Educational surplus does not negate charitable status where education remains the predominant object and surplus is retained and applied for infrastructure and charitable purposes. Cancellation was therefore invalid and registration was restored. As rejection of Form No. 10AB rested solely on cancellation, that rejection could not survive and appropriate registration was required to be granted.

Healthcare services delivered through mobile medical units under a government tender constitute medical relief and charitable purpose where the objects are exclusively healthcare-focused and bar commercial operations. Contractual receipts, tax withholding and surplus do not negate charitable status absent independent profit-making, profit distribution, departure from charitable objects or impermissible application of income. Documentary support for medical activities and reasonable remuneration to specified persons do not establish non-genuineness merely because of a related-party relationship. Regular registration should not be refused on those grounds. Cancellation of provisional registration requires a separate notice identifying statutory grounds and an effective opportunity to respond; without those safeguards, cancellation is unsustainable.

Investor compensation limited to shortfalls after realisation of a defaulting member's assets, while preserving recovery rights and excluding brokers, does not confer a prohibited benefit on the Stock Exchange or its members; trust exemption therefore remains available. A notified Investor Protection Fund may retain exemption for eligible contributions, while specifically directed corpus donations are exempt capital receipts; the restriction on simultaneous exemption claims applies prospectively from assessment year 2025-26. An irrevocable trust deed barring reversion of funds and directing residual assets to SEBI on dissolution satisfies irrevocability requirements. Interest on separately held auction proceeds is not taxable where held in a fiduciary capacity without beneficial ownership under the real-income principle.

For a search initiated after 1 April 2021, Explanation 2 to section 148 deems the Assessing Officer to have information suggesting income escapement for the three immediately preceding assessment years. Where an assessment year falls within that period, jurisdiction must be assumed through reassessment proceedings under sections 147 and 148. An assessment under section 143(3), without issuing a section 148 notice, lacks jurisdiction and is liable to be quashed.

Cash payment for immovable property was satisfactorily explained by accumulated foreign salary earnings of the taxpayer and spouse for purposes of Section 69A. Foreign employment, substantial cash earnings, accepted remittances, travel history, and the absence of evidence of undisclosed income-generating activity in India established a credible and financially sufficient source. Missing customs declarations, currency-encashment records, or a precise historical cash trail did not negate the demonstrated underlying source merely because each accumulated savings tranche could not be traced exactly. The payment was therefore not assessable as unexplained money.

The first proviso to section 149(1) retains the pre-amendment limitation period for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, the six-year limitation under the unamended provision expired on 31 March 2022. Notices issued from 1 April 2021 for that year were outside the period protected by TOLA. Directions creating a legal fiction for reassessment notices could not extend an already expired statutory limitation where TOLA was inapplicable. Consequently, a section 148 notice issued on 31 July 2022 was time-barred, invalidating the consequential reassessment proceedings and order.

Permanent alternate accommodation allotted under a redevelopment arrangement in exchange for surrender of sub-tenancy or occupancy rights constitutes non-monetary consideration, not immovable property received without consideration. Sub-tenancy or occupancy rights are capital assets, and their relinquishment is a transfer; reciprocal contractual obligations prevent the allotment from being characterised as gratuitous merely because no cash payment or separate valuation of surrendered rights exists. Where the accommodation is neither received nor delivered in the relevant year, the provision is additionally inapplicable. A receipt governed by the capital-gains framework cannot be taxed under the residuary provision for property received without consideration.

Interest expenditure cannot be disallowed on an ad hoc or estimated basis unless a nexus is established between interest-bearing borrowings and their diversion for non-business purposes. Current business assets exceeding working-capital borrowings, coupled with the absence of identified non-business investments, interest-free advances, related-party loans, or withdrawals, does not support such a disallowance. Section 14A read with Rule 8D applies only where exempt income is earned or receivable in the relevant previous year. Investments capable of generating exempt income in future do not justify disallowance, and any disallowance where exempt income arises cannot exceed that income.

Prior approval of the Joint Commissioner under Section 153D is a mandatory condition precedent for assessments made by an officer below that rank. A reference in an assessment order to purported approval letters does not prove compliance where the approvals are disputed and the Revenue cannot trace the underlying records. The Revenue must establish that valid prior approval was obtained, and missing approval records prevent verification that the approving authority applied its mind. Failure to prove compliance with Section 153D renders the assessments unsustainable and results in their quashing.

Revisionary jurisdiction under Section 263 is confined, where an assessment is under appeal, to matters not considered and decided in that appeal. Revision of a bogus-purchase addition was therefore impermissible because its validity was already pending before the CIT(A). An assessment order cannot be treated as erroneous and prejudicial to Revenue merely because the PCIT prefers a different view where the Assessing Officer has adopted a legally permissible view on a debatable issue. Directions to invoke Section 69C and apply the consequential special tax rate under Section 115BBE were also unsustainable where the expenditure, source, banking payments and accounting entries had been explained.

Section 153D prior approval operates as an in-built safeguard requiring independent application of mind to the material and draft assessment order for each assessment year. A consolidated approval covering two assessment years, without evidence of file consideration, separate year-wise approval, or recorded reasons, is mechanical and invalid. Invalid approval under Section 153D renders the consequential assessment order void ab initio and liable to be quashed.

Rental receipts recorded in a partnership firm's audited accounts, received in its bank account and assessed in its hands remain taxable to the firm; partners' capital-account withdrawals and uncorroborated rough notings do not establish undisclosed rental income of landowners. Long-term capital gains under a joint development agreement accrue when irrevocable development rights, effective possession and control are transferred under section 2(47)(v), rather than on later handover of constructed area. Section 45(5A) does not apply retrospectively to a pre-amendment transaction. Uncorroborated loose sheets that identify neither payer nor recipient are dumb documents and cannot alone support an addition for underreported rental income.