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.

Long-term capital gain from dematerialised equity shares remained eligible for exemption where the taxpayer substantiated purchase, dematerialised holding and sale through documentary evidence and banking channels. General investigation material and allegations concerning another entity could not establish that the taxpayer's specific transactions were accommodation entries without independent inquiry or linking evidence. The evidentiary onus was therefore discharged, requiring deletion of the unexplained-credit addition. As the alleged commission expenditure addition depended on the sale-proceeds addition, it was also deleted.

Excess stock found during survey retains the character of business income where it matches regular trading stock, is found at business premises, and is explained as acquired from suppressed profits of the same business. Section 115BBE applies only where income is validly brought under a specified deeming provision, including section 69B. Missing purchase records establish non-disclosure but do not alone prove an independent unexplained source. Book entries recording the stock did not reduce the income surrendered, as the purchase debit formed part of closing stock, creditor entries were reversed, and the amount remained credited as taxable income. The excess stock was therefore assessable as undisclosed business income at normal rates, not as unexplained investment under section 69B.

Regional support-service consideration does not constitute royalty under Article 12(3)(a) of the India-Singapore tax treaty or the Income-tax Act where the provider merely applies its own expertise and does not transfer proprietary information or grant a right to use industrial, commercial or scientific experience. Confidentiality restrictions reinforce the absence of any right of commercial exploitation. Such services also do not qualify as fees for technical services under Article 12(4)(b) unless they make technical knowledge, skill, know-how or processes independently usable by the recipient. In the absence of a permanent establishment in India, the receipts are business profits not chargeable to tax in India.

Consideration for complete assignment or surrender of proprietary, beneficial or litigative rights is capital in character, determined by the substance of the right relinquished rather than the deed's label. An intangible proprietary interest may constitute property; a bare right to sue is non-transferable under the Transfer of Property Act. The residuary income head applies only where a receipt is inherently income and does not convert a capital receipt into taxable income. Deduction against interest income requires evidence that expenditure was incurred wholly and exclusively to earn that income; a lower expense amount alone does not establish the required direct nexus.

Pending statutory appeals against a demand must be decided within the stipulated period through a speaking and reasoned order after affording a hearing. Recovery of the outstanding demand remains restrained until final disposal of the appeal, providing interim protection while the appellate remedy is pending.

Transfer-pricing comparables must be selected or rejected under the statutory conditions and Rule 10B factors; fact-based determinations are generally insulated from section 260A review absent legal breach or perversity. Turnover and related-party transaction filters are sustainable when rationally tied to reliable comparability, while working-capital adjustments remain data-dependent. Foreign-exchange gains or losses qualify as operating items only on proof of direct nexus with the international transaction, requiring factual verification where unresolved. The 5% variation under section 92C(2) is a tolerance range, not a deduction, and section 92C(2A) applies retrospectively from assessment year 2002-03; affected matters require fresh determination. Cross-objections are not maintainable under section 260A.

Criminal prosecution for wilful non-production of accounts or false verification cannot rest on assessment findings displaced by appellate adjudication on merits and a fresh assessment; complaints founded on the superseded assessment lack a sustainable factual basis. Corporate vicarious liability requires arraignment of the company where directors are prosecuted for the company's alleged offence; director-only complaints are not maintainable. Civil penalty proceedings and criminal prosecution remain distinct: initiation of penalties for non-compliance or concealment does not, by itself, amount to double jeopardy or bar prosecution. The central principle is that prosecution cannot survive once the factual foundation of alleged concealment, falsity, or wilful non-compliance has been removed.

Reassessment cannot rest on a mere change of opinion where oil and gas exploration expenses and preliminary expenses were specifically examined during the original scrutiny assessment. Replies to the Assessing Officer's queries on the proposed reassessment issues, followed by acceptance without additions, demonstrate that the matters were considered. Failure to reproduce the original queries in an appellate order does not establish non-examination. Reopening on the same material merely because a different view is later taken is therefore invalid.

Discretionary relief under Section 119(2)(b) requires a contextual assessment of special circumstances rather than application of a predetermined formula. Taxing the same interest income in two assessment years after a deductor revised Form 26AS creates genuine hardship where the taxpayer promptly pursued rectification and revision remedies. Delay substantially attributable to pending or rejected remedial proceedings should not defeat relief. Refusing condonation in those circumstances would retain tax paid twice on the same income and result in unjust enrichment of the Revenue. A revised return for the relevant assessment year may be permitted, subject to verification in accordance with law.

Bogus purchase additions involving estimation of the profit element from accommodation-entry purchases were placed before the Supreme Court. The Supreme Court found no good ground to entertain the special leave petitions and dismissed them, leaving the High Court order confirmed. The stated subject concerns taxation of the profit component, rather than the entire value, of purchases treated as non-genuine accommodation entries.

Departmental appeals under section 112(2) of the CGST/UPGST Act, 2017 are not maintainable where the disputed amount falls below the prescribed monetary threshold. The appeal concerning a dispute below Rs.50,000 was summarily dismissed, with no substantial ground found for interference. The monetary threshold limits departmental litigation in low-value disputes unless a basis exists to depart from that limit.

Statutory direct-cost price controls that bar recovery of overheads, administrative expenses and indirect tax costs prevent additional input tax credit from being treated as profiteering for regulated LIG and MIG supplies. Anti-profiteering computation is consequently confined to HIG supplies capable of a commensurate price reduction, without setting one recipient's excess benefit off against another's shortfall. Post-occupancy-certificate sales and unsold units fall outside taxable-supply quantification. Amounts not passed on attract compensatory interest at 18% per annum from collection until refund. A 10% penalty applies under section 171(3A), subject to waiver where the entire profiteered amount is passed on within the prescribed period.