Capital-gains chargeability and computation under the Income-tax Act follow the transfer of the asset. A registered sale deed dated 29 April 2017 established that the inherited immovable property was transferred in the period relevant to Assessment Year 2018-19. Receipt of part of the sale consideration during the preceding assessment year did not establish an earlier transfer, absent material showing that transfer occurred before the registered sale date. The resulting long-term capital gains were therefore not taxable in Assessment Year 2017-18.

Section 14A read with Rule 8D does not permit disallowance of expenditure relating to exempt income where no exempt income was earned or received during the relevant year. Rule 8D prescribes the method for quantifying a disallowance only where Section 14A applies. The later explanation to Section 14A does not operate retrospectively to change this position for the relevant year. Accordingly, expenditure cannot be disallowed under Section 14A in the absence of exempt income.

Section 143(1) permits only limited prima facie adjustments and does not support an adjustment based on mismatches between a return and Form 10BB where examination, enquiry, or rectification is required; the required notice must also be given. For a trust registered under Section 12A, corrected Form 10BB reporting discrepancies may remain curable where substantive Section 11 conditions are met. Application of income to charitable purposes and the permitted 15 per cent accumulation determine exemption, while non-reporting of opening corpus does not affect revenue where no prejudice results. Gross receipts and permissible accumulation are not taxable when Section 11 compliance is established.

The concessional-tax option under section 115BAA requires electronic furnishing of Form No. 10-IC under Rule 21AE. For Assessment Year 2021-22, CBDT Circular No. 19/2023 condones delayed filing where the return was timely filed under section 139(1), the option was selected in Form ITR-6, and Form No. 10-IC was furnished within the Circular's prescribed period. Where these conditions are met, delayed filing does not obstruct a valid election for concessional taxation. Computation at the normal rate may consequently constitute a mistake apparent from the record, capable of rectification under section 154, subject to fulfilment of other substantive conditions.

Recruitment and training costs in an IT-enabled services business are revenue expenditure where they are recurring and create no owned or transferable capital asset; continued training benefits alone do not create a capital-field advantage. Internet access, satellite-link and telephone payments used for daily operations are likewise revenue expenses when they confer no ownership or proprietary interest in communication infrastructure. Reimbursement of expenses to a holding company does not attract tax deduction for contractual work or related disallowance unless a contract, contractor-contractee relationship, consideration for work, or income element is established. The specified outlays therefore remain allowable as revenue expenses.

Long-term capital gains from share sales cannot be classified as unexplained cash credits under Section 68 merely on general penny-stock manipulation allegations. Contract notes, demat records and bank details established the purchase, holding and sale; BSE-platform execution through a SEBI-registered broker and payment of securities transaction tax further supported genuineness. In the absence of adverse findings on that evidence or an independent investigation linking the taxpayer or broker to price rigging, Investigation Wing information and general allegations did not rebut the primary evidentiary record. The Section 68 addition was therefore deleted.

Cash accepted as commission from food-grain trading transactions is not unexplained money where seized material links the receipt to those business activities; Section 69A therefore does not apply, and taxation under Section 115BBE does not follow. The receipt remains taxable as business commission income rather than deemed unexplained income. Where materially unchanged facts were assessed previously using a commission basis of Rs. 2,000 per crore of transactions, consistency requires use of the same basis for the relevant assessment year, restricting commission income accordingly.

Cash deposits linked to disclosed business sales under presumptive taxation may not be treated as unexplained cash credits merely because their ratio to turnover differs from an earlier year. The unexplained-credit provision applies to sums credited in books of account, while taxpayers using the presumptive scheme need not maintain regular books in the prescribed manner. Where declared turnover has not been rejected, purchases and stock are not adversely found, and sales, purchase and stock details support the cash-sales explanation, independent evidence is required to establish an undisclosed source unrelated to the business. In those circumstances, the deposits are treated as disclosed business receipts rather than unexplained credits.

Section 12AB registration rejected for alleged non-submission of information requires a proper opportunity to furnish the material, particularly where charitable character and registration history are established. Subsequent registration may operate from the date of the original application. Once charitable objects and genuine activities are accepted, registration should not be made conditional on prospective compliance measures concerning commercial receipts or updating of returns; any cancellation must follow the prescribed legal process. Approval under section 80G requires fresh consideration on relevant material and after a proper hearing where section 12AB registration has been directed from the original application date.

Faceless reassessment under the Income-tax Act required a notified scheme governing assessment, reassessment, or recomputation of escaped income. The e-Assessment of Income Escaping Assessment Scheme, 2022, was notified only after the reassessment in question had been completed. Earlier faceless-assessment arrangements did not extend to reassessment proceedings. The Faceless Assessing Officer therefore lacked jurisdiction to complete the reassessment before the notified scheme took effect, and the reassessment was quashed.

Jurisdictional defects in reassessment initiation may be examined collaterally in revision proceedings to test whether the underlying order has a legally sustainable foundation; participation, waiver, acquiescence, or failure to appeal cannot validate an inherent lack of jurisdiction. Where reassessment is initiated after the prescribed period, approval from the specified authority under section 151(ii) is a condition precedent. Approval under section 151(i), an office-holder's description, or subsequent departmental communication does not establish compliance. Revisionary jurisdiction under section 263 requires both error and prejudice and cannot cure invalid sanction or create lawful prejudice from defective reassessment proceedings.

Valid service of a jurisdictional notice under Section 148 is essential to commence reassessment. Service by affixture requires due diligence in attempting ordinary service, reliable witness verification, and affixture at the correct premises under the substituted-service requirements in Rules 17 to 20. Sending notice to an address different from the residential address in the registered sale deed, without satisfying those requirements, invalidates service. Participation in assessment proceedings does not cure invalid service under Section 292BB. Consequently, invalid service prevents reassessment jurisdiction under Section 147 from arising.

Accrual under section 145 arises only when a contractual reimbursement entitlement is ascertainable; later reconciliation of deposit liabilities is therefore recognised in the subsequent period. Under the mercantile system, prior-period expenses become deductible on identification, quantification and crystallisation, subject to the sustained residual disallowance. Genuine expenditure for business promotion, agency operations, reimbursed group expenses and depositor-grievance redressal is deductible, though reasonable restrictions may apply to celebratory or personal elements. NBFC-based limits do not restrict a partnership firm's substantiated agency commissions and incentives. Consumables and replacement UPS batteries are revenue expenditure, whereas communication equipment is capital. Unremitted public deposits held for transmission to a principal are not loans or advances and do not constitute deemed dividend.

Section 56(2)(x) permits use of the stamp duty value prevailing on an agreement date instead of the registration date where the dates differ, but only if consideration, or part of it, was paid on or before the agreement date through an account-payee cheque or prescribed banking channel. Application of this proviso requires verification of the Banakhat dates, their connection with the registered sale deeds, and evidence of cheque presentation, encashment, bank entries, accounting records and receipts. Agreement-date valuation applies only when the statutory payment condition is established.

Section 80-IA may cover a separately identifiable telecom undertaking operating under an independent licence, with audit certification by an independent Chartered Accountant. Functionally integrated digital switching equipment, commercial-use rights and goodwill acquired with a business may qualify for depreciation; block-of-assets depreciation is not reduced for book impairment absent a statutory adjustment. Interest on temporary business funds retains business-income character, while further exempt-income disallowance cannot arise where no exempt income exists. Refund interest runs until actual payment, and substantiated TDS credit may be allowed despite Form 26AS omission. Transfer-pricing benchmarks require currency-specific comparables for foreign-currency loans and supportable comparable rates for guarantees, comfort or support letters, and delayed receivables.

Reassessment under sections 147, 148 and 148A requires credible information with a live link to alleged income escapement and independent application of mind. An anonymous, unverified tax-evasion petition alleging undisclosed immovable-property investment cannot meet that jurisdictional threshold where it lacks particulars of the properties, valuation, acquisition, payment source, or investment beyond recorded books. Independent material is necessary to convert vague allegations into credible grounds for reopening; absent it, reassessment initiation and consequential assessment are invalid.

Transactional Net Margin Method benchmarking for administrative support services requires comparables to be functionally similar and capable of meaningful comparison after considering scale, risk profile, intangibles, brand value, service nature and financial stability. Entities with substantially higher turnover, diversified or high-end services, significant intangible or brand advantages, abnormal or volatile results, or functional differences must be excluded. Web-based software development and high-end analytical and research service providers were unsuitable. After their exclusion, the remaining comparable margins were lower than the tested party's margin, so no upward transfer-pricing adjustment was warranted.

Embezzlement and misappropriation losses suffered by a charitable institution are allowable where special-audit findings and a first information report substantiate fabricated records, unauthorised use of fixed deposits, and diversion of funds or blood stock. The material consideration is the institution's conduct and evidence establishing the embezzlement, rather than the eventual result of criminal proceedings. Losses caused by persons managing the institution are treated as absolute and irrecoverable on the established facts, and cannot be characterised as benefits extended to specified persons.

For the relevant pre-amendment period, section 194B applied its withholding threshold to each individual winnings payment rather than aggregated payments; disallowance under section 40(a)(ia) also requires an identifiable expenditure and withholding default. Deposit-linked and referral bonuses granted on promotional conditions are not winnings merely because recipients participate on an online gaming platform. CSR expenditure excluded from business-expense deduction under section 37(1) may nevertheless qualify under section 80G where the statutory conditions, including donee eligibility, are met. Employee Stock Option Plan expenditure follows established allowable treatment absent distinguishing facts. Total-income computation requires verification of all operative assessment, appellate, and rectification orders.

Reassessment cannot be used to review foreign-remittance deductions already examined in the original assessment on the same disclosed material, without new tangible material indicating escaped income; reopening on that basis is invalid as a change of opinion. A pending appeal concerning tax-deduction default proceedings does not bar a reassessment disallowance, because those proceedings concern tax collection while disallowance concerns income computation. The same expenditure cannot be disallowed twice, requiring verification of alleged arithmetical errors, including tax-deducted amounts and expense reversals. Claimed carry-forward losses also require verification against assessment records before determination.