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.

Chapter X arm's-length adjustments are confined to international transactions with associated enterprises and cannot increase profit from independent-party dealings. Operating margins must reflect DRP-directed exclusions of warranty provision, bad debts written off, and marketing expenditure solely attributable to non-associated-enterprise sales. Business-related liability or provision write-backs and export incentives constitute operating revenue, without deducting separately disclosed other operating income from total revenue. Functional comparability depends on products and business activities. Where a working-capital adjustment under TNMM accounts for delayed associated-enterprise receivables, a separate notional-interest adjustment would duplicate the effect. Brought-forward unabsorbed depreciation cannot be set off against income from other sources.

Registration renewal under section 12AB cannot be refused solely because a public charitable institution lacks a formal trust deed or memorandum of association. Section 12AB(1)(b), read with Rule 17A(2), recognises institutions created otherwise than under an instrument and permits them to furnish documents evidencing their creation or establishment. Public-trust registration, original registration records, prior income-tax registrations, and evidence of continued existence may establish the institution's status. Where there is no adverse finding on charitable or religious objects or the genuineness of activities, absence of a formal constitutive instrument does not bar renewal of registration.

Section 56(2)(viib) applies only when a closely held company receives consideration for issuing shares above their fair market value; it does not cover fully and compulsorily convertible debentures (FCCDs) before conversion. Rule 11UA does not deem FCCDs to be shares, and issuance of FCCDs and later conversion into equity are separate events. Until conversion, FCCDs retain independent contractual characteristics, including coupon returns. Their treatment as equity under regulatory or insolvency frameworks cannot expand the Income-tax Act's charging provision. Consideration received for FCCDs before conversion therefore falls outside section 56(2)(viib), and no valuation-based addition arises.

Tax character of allotment rights in under-construction real-estate units depends on the transaction's substantiated business nature, not book entries alone. Where the units were not shown as closing stock, payments were recorded as loans and advances, and the loss was claimed inconsistently, the rights are treated as capital assets rather than business stock. The resulting loss is therefore long-term capital loss, with indexation and carry-forward treatment available. Interest included in acquisition cost requires fresh examination where conflicting positions exist, after the taxpayer is given an opportunity to provide supporting evidence.

Redevelopment agreements executed by a cooperative housing society as representative of its members under Section 79A guidelines grant development rights without transferring the society's land or generating consideration for the society. Permanent alternate accommodation, hardship compensation and displacement compensation belong to individual members, whose rights in the flats are affected. AIR information alone does not establish that reported consideration constitutes taxable capital gains of the society. Any capital-gains tax consequences from redevelopment arise, if at all, for the individual members rather than the cooperative housing society.

Section 14A disallowance is confined to investments producing exempt income; foreign investments yielding taxable dividends must therefore be excluded from the Rule 8D computation, subject to verification and recomputation of eligible investments. Japanese Yen royalty receipts recorded in the accounts and offered to tax cannot be treated as undisclosed income without supporting evidence. A disallowance already made by the assessee for delayed employee contributions cannot be duplicated, although separately identified late-deposited contributions may remain disallowable. The applicable principles prevent both unsupported additions and double disallowance.

Substantial compliance with the requirement to furnish Form No. 10CCB supports deduction under section 80IB where the audit report was signed before the return-filing due date and uploaded as a scanned attachment to the tax-audit report. Where no separate electronic filing facility or offline utility was available, delayed standalone electronic filing after the facility became available does not defeat the deduction. A technical filing deficiency not attributable to the taxpayer cannot override substantive compliance with the audit-report requirement.