Subsisting registration of a charitable trust supports renewal where the registration remains valid and has not been withdrawn or cancelled in accordance with law. Renewal under section 12A(1)(ac)(ii) applies to an existing registered trust whose registration is due to expire. An erroneous selection of a sub-clause in an earlier regular-registration application does not erase the legal existence of registration granted by the competent authority. Refusal cannot rest solely on the trust's absence of registration under the erstwhile regime before 1 April 2021, particularly where no objection concerns its objects, genuineness of activities, or compliance with registration conditions.

Registration applications restored for fresh adjudication retain the statutory character of the regime under which they were originally filed. A remand continues the original registration proceedings and does not convert an application under the earlier charitable-registration framework into one under a later framework merely because the consequential order is made later. Where exemption for a relevant assessment year was denied solely for want of registration, the exemption claim must be reconsidered after consequential registration is granted and the applicable statutory conditions are verified.

Section 80P(2)(d) permits a co-operative society to deduct interest or dividend derived from investments with another co-operative society. A co-operative bank remains registered as a co-operative society under the applicable co-operative societies law. Section 80P(4) restricts a co-operative bank's deduction claim on its own income but does not prevent another co-operative society from claiming deduction for interest received from that bank. Interest and dividend earned from investments with a co-operative bank therefore qualify for deduction under Section 80P(2)(d).

Prior approval under Section 153D is a mandatory condition precedent for assessments by an Assessing Officer below the prescribed rank. Where compliance is specifically challenged, the Revenue must prove that valid approval was granted. Statements that approval letters are untraceable, recitals in assessment orders, and file-movement evidence cannot replace the statutory approval or demonstrate its validity and application of mind. Failure to establish compliance with Section 153D renders the resulting assessments unsustainable and liable to be quashed.

Section 41(1) applies only where the relevant expenditure or trading liability was previously allowed as a deduction and the taxpayer subsequently obtains a benefit through remission or cessation. Interest earlier disallowed under section 43B, continuing in the balance sheet without write-back, waiver, settlement or discharge, cannot be added under section 41(1); assignment of debt by a lender does not extinguish the borrower's liability. Depreciation remains available for a building continuing in the existing block of assets and available for business use. Lack of operating revenue or creation of a mortgage, without permanent business closure, sale, discard or loss of availability, does not justify denying depreciation.

Non-adjudication of grounds raised by an assessee constitutes an error apparent from the record. The earlier appellate order required a limited recall only for the grounds left undecided, rather than a full reconsideration of the appeal. The miscellaneous applications were allowed to that extent, and the prior order was recalled solely for adjudication of the omitted grounds.

Unproved accommodation-entry purchases cannot be subjected merely to an estimated profit-rate disallowance when their non-genuine nature is accepted; the purchases must be allowed or disallowed in full. Accordingly, full additions were restored for assessment years 2013-14 and 2014-15, while restricted additions for earlier years remained undisturbed because the Revenue had not contested them. Settlement Commission findings are conclusive only for matters and assessment years before it and cannot determine additions for later years. Search-based additions require independent factual examination. Because relied-upon material was not fully supplied and cross-examination was denied, the remaining additions for later years require fresh assessment after disclosure and adequate hearing.

Section 69A requires a satisfactory explanation of the nature and source of cash deposits. Cash gifts cannot be rejected solely because they were received in cash or donor confirmation is unavailable after the donor's death; the donor's financial capacity and availability of funds must be assessed on the preponderance of probabilities. Claimed family reimbursements for advance-tax and housing-loan payments require verification against bank payments, tax challans, loan records, the reimbursing persons' financial capacity, and the nexus with cash deposits. Delayed evidence or absent confirmations alone does not justify rejection without objective verification. The addition requires reconsideration to the extent sources and nexus are established.

Renewal of registration under Section 12AB cannot be rejected solely because a charitable or religious institution lacks a separate written trust deed or memorandum of association. Section 12AB(1)(b), read with Rule 17A(2), distinguishes institutions established under an instrument from those established otherwise and permits examination of alternative documents evidencing creation and existence. Public-trust registration, the related registration application, existing tax registration, and evidence of continuing activities may establish eligibility. Where no adverse finding concerns charitable or religious objects or the genuineness of activities, cogent documentary evidence is sufficient for renewal.

Business income processed under section 143(1) without a show-cause notice and mechanically adopted in a subsequent section 143(3) scrutiny assessment cannot be sustained where the returned computation disclosed nil business income. Because both adjustments concerned the same matter, the section 143(1) intimation merged into the scrutiny assessment, allowing the assessee to challenge the addition in appeal against the assessment order. The appellate authority could verify the record, delete the unsupported addition, and recompute income in line with the returned income.

Section 153C permits proceedings against an "other person" where a search warrant is issued in another person's name but executed at that person's premises; the panchanama cannot change the identity of the searched person. For completed, unabated assessment years, additions require incriminating material discovered in the search that relates specifically to each relevant year; material for one year and uncorroborated search admissions cannot justify additions for earlier years. In estimating liquor-business income, a declared net-profit rate of about 5.5% was considered reasonable where gross profit was verified, ordinary operating expenses were commercially plausible, and separate disallowance of expenses already excluded in computing profit would cause double taxation.

Income estimation after rejection of accounts must use a fair profit rate supported by past results or comparable material, rather than an unsupported rate; the rate applied to undisclosed or estimated receipts was reduced. Section 292C presumptions are rebuttable, and impounded material cannot be selectively read or sustain additions without transactional corroboration. Standard retail software acquired for internal use is a copyrighted article, not royalty or technical services requiring tax deduction. Protective additions require a linked substantive assessment, while bank stock statements, loose notings and proposed expenditure estimates alone do not prove unexplained investment or expenditure. Account credits require peak-credit and telescoping analysis; renovation records require limited verification. The enhanced Section 115BBE regime was inapplicable to financial year 2016-17.

Approval under section 80G cannot be denied merely because a trust's objects include construction or maintenance of a temple and worship-related activities. Such objects do not alone establish a dominant religious purpose where the trust also undertakes relief work without distinction of caste, creed or religion. Rejection requires material showing religious segregation of beneficiaries, exclusive propagation of a particular belief, or absence of charitable character. Whether expenditure on religious activities exceeds the statutory threshold requires assessment of actual activities and financial records and cannot, without that analysis, justify refusal of approval.

Revaluation surplus credited and received by a retiring partner is not exempt under Section 10(2A), which covers only the partner's share in the firm's total income. For the relevant assessment year, revaluation and distribution of enhanced asset value attracted Section 45(4), making the resulting capital gains taxable in the partnership firm rather than the retiring partner. The revaluation surplus was therefore not assessable in the partner's hands, and the addition was deleted.

Rule 46A permits admission of material additional evidence where a filed application and supporting affidavit establish its relevance to disputed audit and accounting findings. Rejection of books of account does not justify ad hoc profit estimation; any estimate requires a rational comparative or historical basis, including prior gross-profit or net-profit results. Cash deposits supported by cash-book entries, regular business receipts and prior withdrawals cannot be treated as unexplained merely because they were deposited in instalments during demonetisation. Section 68 applies to sums credited during the relevant year, not to an opening trade-creditor balance reclassified as an unsecured loan without any fresh receipt or credit.

For the section 54F residential-house ownership condition, a property held by a company remains the company's property because of its separate legal identity; a director cannot be treated as its owner solely on that basis. A jointly held flat may be counted as the taxpayer's residential house, but, on the stated facts, it remained the only such house apart from the property receiving the qualifying investment. The ownership condition was therefore met, making the capital-gains deduction available.

Section 14A disallowance does not arise where no exempt income is earned and, where exempt income is earned, cannot exceed that income. Electrical installations qualify for 15% depreciation, while UPS, as a computer accessory or peripheral, qualifies for depreciation at the computer rate. Bank guarantee fees paid to banks are not commission under section 194H and do not trigger tax deduction at source or disallowance under section 40(a)(ia). Substantial interest-free funds support a presumption that capital work-in-progress was financed from those funds absent a borrowing nexus. For section 80IC, separately accounted unit losses not disclosed as income-tax losses cannot reduce the deduction; allocation of common expenses requires fresh examination.

Employees' provident fund and employee state insurance contributions credited on the next working day after Saturday and Sunday bank holidays remained allowable as deductions. The payments were cleared and deposited on 17 June 2019, and the timing did not result from an intentional default. Disallowance of the employee-contribution payments was therefore unsustainable.

Belated furnishing of the audit report in Form No. 10B does not by itself disentitle a charitable trust from exemption under sections 11 and 12 where the report was obtained before the return was filed. The filing requirement is procedural and directory, not mandatory, when substantial compliance exists. Denial of the statutory exemption solely because the prescribed audit report was furnished late is therefore unwarranted, particularly where equivalent exemption claims were accepted in adjacent assessment years. The exemption claim under section 11 was consequently allowed.

Section 270A distinguishes ordinary under-reporting from under-reporting caused by misreporting. Cash deposits disclosed through a revised computation, with consequential tax paid and the computation accepted in assessment, do not establish misreporting unless the applicable limb of section 270A(9) and its ingredients are identified. Where the taxpayer does not contest the addition and timely seeks immunity after paying tax and interest, the disclosure may constitute under-reporting at most. A penalty calculated for misreporting is therefore unsustainable, and immunity from penalty is available.