Assessment validity under Sections 143(3) and 153A depends on verifying whether it was founded on the original notice or a later notice issued after the initial proceedings were dropped. Where the search authorisation did not cover the assessee, the effect of the fresh Section 153A notice, subsequent Section 142(1) notices, and any return filed in response requires factual examination. The appellate authority may exercise powers under Section 250(4) to conduct or direct further inquiry, including obtaining a remand report, before deciding jurisdictional objections and remaining grounds.

Closing stock damaged while factory premises were under bank possession may be valued at cost or net realisable value, whichever is lower, where that accords with the consistently disclosed accounting method. Internet-price revaluation does not justify an addition unless it disproves the reduced recoverable value; the closing-stock addition was deleted. Cash deposits during demonetisation recorded as cash sales in audited books, supported by sale bills, delivery challans, sales registers and stock registers, were not unexplained money absent contrary material. The deposits were explained by the non-performing bank account and takeover of the business and residential premises, so the addition under Section 69A was deleted.

Substantiation of tax claims is required for deductions, exemptions, and explanations of entries in seized records. A section 80C deduction is available only to the extent qualifying payments are evidenced; unsupported amounts are disallowed. HRA exemption requires documentary proof of rent payment and entitlement, with the taxpayer bearing the onus. Entries in seized Excel sheets recording loans advanced may be treated as unexplained investment where no material establishes a different classification or underlying business nature. Unsupported claims and explanations therefore fail.

Long-term capital gains from listed-share sales supported by contract notes, demat statements and bank records cannot be characterised as non-genuine accommodation entries solely because of general investigation material or abnormal price appreciation. Purchases through a recognised broker, banking-channel payments, demat credits, exchange sales and banking-channel sale proceeds constitute direct documentary evidence unless disproved as false or fabricated. Such treatment requires evidence linking the taxpayer to operators or price-rigging, such as a cash trail, commission payment, pre-arranged transactions, or participation in manipulation. Suspicion and the human-probabilities test cannot replace proof.

Unexplained cash-credit treatment of share-sale proceeds and consequential share investment requires evidence directly connecting the taxpayer with accommodation-entry transactions. Third-party statements and general investigation material may trigger enquiry but, without corroboration, cannot displace unrebutted purchase bills, contract notes, bank records, and banking-channel fund movements; suspicion cannot substitute proof. Finality of appellate deletion concerning the original share purchase removes the factual basis for treating subsequent sale proceeds and related investment as unexplained, requiring deletion of the additions.

Section 69A places the burden on a person found in possession of cash to provide a credible, corroborated explanation of its source and ownership. A claim that cash belonged to third parties is insufficient where their particulars are incomplete, they cannot be verified, and no evidence establishes the source or ownership of the money. Mere denial of ownership, particularly when no claimant emerges over time, does not rebut the presumption arising from possession. Cash lacking a satisfactorily supported explanation may therefore be assessed as unexplained money.

Undisclosed real-estate sale receipts constitute gross collections, so where no evidence shows that corresponding costs or investments were also undisclosed, taxability is confined to the embedded profit; the prior profit estimate was accepted as adequate. Likewise, non-genuine purchase invoices do not justify disallowing the full purchase value when material consumption, construction activity, sales and book results remain accepted; only the grey-market saving or embedded profit may be estimated. Seized electronic data certified under the Evidence Act and corroborated by unretracted search statements remain admissible and reliable. A delayed, unsupported retraction does not displace their evidentiary value.

Amended tax-inclusive income computation requires taxes, duties, cess and fees incurred in relation to goods or services to be included when calculating business income. Consequently, GST and service-tax liabilities collected from customers and paid after the return-filing date remain subject to disallowance under section 43B even if not routed through the profit and loss account. Interest on delayed remittance of TDS is treated as penal and not deductible as business expenditure. Commission-expense discrepancies require reconciliation, cash visa-fee payments require verification of each individual payment for cash-payment restrictions, and differences between declared receipts and Form 26AS receipts require reconciliation with books and supporting evidence.

Reassessment jurisdiction requires a reason to believe founded on correct facts and independent verification. Recorded reasons based on the incorrect premise that only summary processing occurred, despite a completed scrutiny assessment, cannot be cured as a clerical defect. Similarly, unverified Investigation Wing information unsupported by corresponding bank credits does not establish a valid basis for reopening. Sale proceeds of investments previously recorded in the books and balance sheet, received through banking channels, are not loans, deposits, share application money, or unexplained cash credits. Such disclosed investment realisations cannot be added as unexplained credits.

Section 80G may allow a deduction for qualifying donations even when they form part of corporate social responsibility expenditure. Explanation 2 to section 37(1) disallows CSR expenditure in computing business income but does not impose a general bar on a specific donation deduction, except for donations expressly excluded under section 80G. Where statutory conditions are otherwise satisfied, CSR character alone does not defeat the claim. Given divergent judicial views, allowing the deduction constitutes a plausible and legally sustainable view. Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests and cannot replace one permissible view with another; revision was therefore invalid.

Section 12AB registration requires a prima facie enquiry into charitable objects, the genuineness of actual or proposed activities, and material legal compliance; it is not a full assessment of every receipt or expenditure. Verified charitable medical activities, including eye camps, patient treatment, medical equipment and hospital facilities, support genuineness where explanations remain undisplaced by contrary evidence. Related-party rent or incomplete supporting records do not alone prove a sham arrangement, private benefit, or diversion of funds. Section 80G(5) approval cannot be refused solely because section 12AB registration was denied where no independent breach of section 80G(5) conditions or rule 11AA is identified.

Partners' admitted capital contributions, where the contributors are identified, explain the nature and source of credits in a partnership firm's books for Section 68 purposes. Questions concerning a partner's creditworthiness or the source of contributed funds must be examined in that partner's individual assessment, rather than through an unexplained-cash-credit addition to the firm. Accordingly, an addition based solely on doubts about partners' sources is not sustainable against the firm, while assessment of those sources remains open in the partners' individual cases. A short delay attributable to serious illness may be condoned where sufficient cause exists and substantial justice favours merits adjudication.

Assessment of an other person on search-seized material must follow the prescribed procedure under section 153C, with satisfaction recorded separately for each relevant assessment year. The relevant assessment period is reckoned from the date the jurisdictional Assessing Officer receives the seized material. A consolidated satisfaction note covering multiple years does not satisfy that requirement, rendering the assessments for 2014-15 to 2017-18 invalid. Where additions for 2018-19 relied on seized material, assessment under section 143(3) without initiating section 153C proceedings and issuing the prescribed notice lacked jurisdiction. The relevant assessments were consequently unsustainable.

Charitable-registration applications rejected for absent or pending State public-trust registration, insufficient evidence of genuine activities, or curable filing defects require category-specific reconsideration. A subsequently obtained State-registration certificate must be verified for authenticity, validity and applicability, while a pending application should permit later production of the certificate. Genuineness requires examination of accounts, actual activities, supporting material and their nexus with stated objects, with disclosure of adverse material and a fair opportunity to respond. Curable defects in Form 10AB should be rectified where legally permissible. Consequential tax-exemption approval refusals require fresh consideration while retaining independent statutory conditions.

Rectification under Section 154 addresses apparent duplication where cash deposits are assessed both in a dissolved firm's assessment and in the successor proprietorship's assessment. Separate books showing that the deposits belonged to the successor proprietorship, together with disclosure and assessment of those deposits as undisclosed income in its scrutiny assessment, support treating the duplication as an error apparent from the record. The issue concerns correction of an existing factual error rather than fresh adjudication or reopening; the original assessment mode and absence of an appeal do not prevent rectification.

E-verification of an income-tax return relates back to its original filing date and does not make the return filed on the later verification date. Where the original filing occurred within the COVID-19 extension for statutory compliances, interest for delayed filing under section 234A is not leviable. A rectification under section 154 based on treating verification as the filing date is therefore illegal and unsustainable.

Unexplained-expenditure additions require evidence that the expenditure's source is unexplained, not merely vendor non-response to verification notices or later return-filing deficiencies. Expenditure recorded in unrejected books, paid through banking channels, and supported by invoices, vendor particulars, agreements, GST records and transaction data was treated as sufficiently evidenced unless the Revenue produced positive material discrediting it; the addition was therefore deleted. Rules on additional evidence do not require a remand report where no new document is admitted and the material comprises evidence already filed or explanations based on the assessment record.

Claimed exempt long-term capital gain on equity-share sales was not established as genuine merely through records of merger-based allotment, dematerialisation, and sale through a recognised intermediary. Investigation findings concerning the scrip, abnormal price movements, trading patterns, and absence of supporting financial fundamentals indicated conduct inconsistent with ordinary market behaviour. Failure to produce evidence of the company's intrinsic financial strength or rebut adverse findings, together with no new material against appellate findings, resulted in sustenance of the Section 68 addition.

Agricultural land's capital-asset status must be determined by measuring its distance from municipal boundaries in force on the transfer date; a certificate based on superseded boundaries is insufficient. The land's taxability consequently requires fresh determination on admissible evidence. Reassessment may proceed where property-sale information, non-filing of a return and an unsubstantiated exemption claim create a prima facie basis that income escaped assessment; prior approval is valid where recorded reasons receive due consideration. Indexed acquisition cost for inherited land and residential-investment exemption require evidence and verification of statutory conditions, with the taxpayer bearing the burden of proof.

Unrealised foreign-exchange gains arising on year-end reinstatement of foreign-currency ECB liabilities used to acquire capital assets in India must be recognised in taxable income under section 43AA. Section 43A's actual-cost adjustment mechanism applies only when its conditions, including acquisition of an asset from outside India, are met. Foreign-currency denomination or an overseas ECB source does not make assets acquired in India imported assets. Failure to satisfy section 43A does not remove the transaction from section 43AA.