A section 148 notice issued on 23 July 2022 for assessment year 2015-16 was described as invalid because notices issued on or after 1 April 2021 for that year fell outside the period permitted by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The reassessment had originated under the earlier regime, followed by proceedings under section 148A and a fresh notice. The text notes that the Revenue conceded the point and that cited decisions supported dropping such notices. Consequently, the notice was quashed and the reassessment could not survive.

Faceless reassessment schemes issued under section 151A require initiation of proceedings, including orders under section 148A(d) and notices under section 148, through automated allocation and the mandatory faceless mechanism under section 144B. A Jurisdictional Assessing Officer cannot initiate such proceedings outside that prescribed mode after the schemes commenced. Departure from the mandatory statutory procedure invalidates the initiation and deprives the consequential reassessment of valid jurisdiction. Accordingly, an order under section 148A(d) and notice under section 148 issued by a Jurisdictional Assessing Officer are illegal, and the resulting reassessment is liable to be quashed.

Additional evidence on the land's distance and agricultural character is relevant to whether it falls within the definition of a capital asset under the Income-tax Act. The purchase deed and valuation report described the land as agricultural, while the distance certificate required verification. The material was admitted for limited verification, with the Assessing Officer required to determine the land's nature in accordance with law after giving the assessee an opportunity of hearing.

Reassessment was invalid where the original scrutiny had examined and accepted the charitable trust's exemption claim, no new tangible material emerged, and the actual recorded reasons were not supplied. Reassessment was also unavailable while scrutiny of a revised return remained pending. Income from sales of books, notebooks and uniforms qualified for exemption under Section 11 where the activity was incidental to the trust's educational objects and the surplus was applied towards establishing a school, without diversion to non-charitable purposes. On materially identical facts, exemption remained available and the excess-income addition was deleted.

Deduction under Section 80JJAA may be allowed where the return, tax-audit report and Form 10DA are filed after the Section 139(1) due date but within the period permitted by Section 139(4). The timing requirement for claiming the Chapter VI-A deduction is treated as directory where the deduction claimed does not exceed the amount certified in Form 10DA. A bona fide delay caused by genuine hardship, including an extended annual general meeting deadline, does not support an adjustment under Section 143(1)(a).

Revenue under the Percentage Completion Method should be recognised only where significant risks and rewards have transferred through legally enforceable sale agreements. Under Accounting Standard 9 and the Guidance Note on Accounting for Real Estate Transactions, mere booking, buyer identification, determination of area or consideration, or receipt of token advances is insufficient. The Guidance Note also requires realisation of at least 10% of the agreement value under legally enforceable documents at the reporting date. Flats with agreements executed later and flats failing that realisation condition should not be included; otherwise, revenue already offered in a subsequent year may be taxed twice.

Clause (iv)(B) of the first proviso to section 80G(5), effective from 01.10.2024, permits a trust that has commenced activities to apply for approval at any time after commencement. Where a delayed Form 10AB application was filed after the earlier extended deadline but rejected after the amended clause took effect, it should be considered under the new regime rather than rejected solely as time-barred under the former filing requirement. The application dated 28.09.2024 is to be treated as an application under clause (iv)(B) and decided in accordance with law.

A consistently employed Project Completion Method cannot be rejected unless statutory conditions are met and true profits cannot be deduced; income and conversion gains must therefore be recognised consistently with that method rather than by sale-agreement dates. Capital gains on conversion of a capital asset into stock-in-trade arise when the converted stock is sold or otherwise transferred. Interest capitalised to project work-in-progress cannot be disallowed on an unsupported estimate where no non-business use or fund diversion is established. Capitalised interest and common-asset costs form part of indexed cost, section 45(2) applies uniformly to the converted asset, and tax deducted at source credit requires verification rather than denial on an assumed timing mismatch.

Excess sugarcane price paid by a co-operative sugar factory to member suppliers under Section 37(1) requires disallowance only to the extent the payment contains a profit-embedded component. The prescribed approach compares the rate paid to members with the commercial benchmark represented by payments to non-members or outsiders, calculates the differential for cane procured from members, and permits reduction where contemporaneous evidence shows that the differential reflects commercial factors such as quality or recovery rather than membership. As the necessary computations and evidence were unavailable, the Assessing Officer must recompute the disallowance using this methodology.

Section 54 exemption remains available where capital gains are invested in a new residential property within the prescribed period, even if they were not deposited in the Capital Gains Account Scheme by the due date under section 139(1). The analysis treats the time available under section 139 as including the extended filing period under section 139(4). Actual utilisation of the capital gains for the qualifying residential investment therefore constitutes sufficient compliance, and failure to make the specified deposit by the original return-filing due date does not defeat the exemption.

Revision under Section 263 was valid because the assessment allowed depreciation on BOT toll-road development cost as an intangible asset without examining the binding CBDT Circular requiring amortisation over the concession period where road ownership does not vest in the assessee. Failure to apply the circular constituted inadequate inquiry. Prevailing High Court decisions also treated BOT-road development expenditure as not creating a depreciable intangible asset, so acceptance of a contrary Tribunal view was not a sustainable possible view. The assessment was therefore erroneous and prejudicial to Revenue interests, supporting revision.

Section 41(1) applies only when a trading liability is remitted or ceases and the assessee obtains a corresponding benefit. Long-outstanding sundry creditors, supported by confirmations and ledger accounts, do not become taxable merely because they remain unpaid or may be time-barred; nor can liabilities relating to earlier years be assessed as unexplained credits in the relevant year. The creditor-liability addition was therefore deleted. Differences between contract receipts in Form 26AS and recorded receipts require verification where the assessee claims that payer deductions represent VAT, insurance, TDS or other allowable business expenditure. The unreconciled amount was restored for verification and allowance if substantiated.

Refusal of charitable registration for non-furnishing of activity details, despite a requested adjournment, denied an effective opportunity to submit relevant material. The registration application must therefore be reconsidered on merits after providing a proper opportunity, consistent with natural justice. An approval application rejected under an earlier filing timeline had to be assessed under the subsequently inserted provision permitting a trust that has commenced activities to apply at any time, because that provision was operative when the rejection was made. The donor-approval application must be treated under the amended framework and decided according to law.

For trusts already undertaking charitable activities when provisional approval under section 80G(5) is obtained, the six-month application period tied to commencement of activities should not be applied retrospectively. A harmonious and purposive construction treats the requirement as applicable to institutions commencing activities after receiving provisional approval; existing institutions must apply at least six months before that approval expires. The Finance Act, 2024 amendment allowing applications at any time after commencement supports this interpretation. Accordingly, a Form 10AB application filed within that period is maintainable and requires verification of substantive eligibility rather than rejection solely as time-barred.

Delayed filing of Form No. 10B does not, by itself, defeat a charitable trust's exemption where its accounts were audited, the audit report was uploaded before the income-tax return, and the substantive conditions for charitable application of income were met. Timely filing of the audit report is treated as a procedural and curable requirement rather than a substantive condition precedent in those circumstances. The claimed exemption, actual application of income and permissible statutory accumulation must therefore be granted, with charitable income recomputed accordingly. Delay in filing the appeal was also condoned where it resulted from the tax representative's inadvertent failure to communicate notices rather than deliberate inaction by the trust.

Disallowance relating to exempt income may be restricted to the taxpayer's voluntary disallowance where the assessing authority has not recorded statutory dissatisfaction with that computation before applying Rule 8D; such disallowance is not included in book-profit computation. Brand equity fees paid for contractual use of business names, marks and marketing indicia may qualify as revenue expenditure. Discounts on gift cards and vouchers crystallise on sale and may be deductible in that year despite later redemption, with expired unused balances offered to tax. Taxable refund interest may be assessed on a net basis after setting off interest charged for advance-tax default under applicable precedent.

Reassessment notices issued beyond three years require material showing escaped income, represented in prescribed forms, meeting the statutory threshold. Housing-finance loan disbursement records and builder receipts established that substantial property consideration came from a housing loan, but the order initiating reassessment disregarded that evidence. Subsequent scrutiny examined only loans from relatives and did not dispute the housing loan, leaving the balance amount requiring examination below the statutory threshold. The reassessment notice was therefore time-barred, and the consequential reassessment order was quashed.

Mandatory faceless reassessment procedures require reassessment notices to be issued through automated allocation and a faceless mechanism. The central-charge exclusion described applies to assessment orders, not to issuance of reassessment notices, so it does not permit a Jurisdictional Assessing Officer to issue such notices outside the prescribed process. A challenge to the officer's inherent authority under the faceless regime is distinct from an objection to territorial or case-assignment jurisdiction. Accordingly, the statutory time restriction for jurisdictional objections does not bar a challenge alleging that the notice was issued without inherent jurisdiction. Non-compliance with the mandatory faceless notice mechanism renders the resulting reassessment proceedings unsustainable.

Delayed receivables from associated enterprises constitute an international transaction, but any notional-interest adjustment must reflect corresponding payables to the same associated enterprise arising in the ordinary course of business. The assessing authority or transfer pricing officer must verify the nexus between those receivables and payables and compute an adjustment only on the net receivable amount. Where an adjustment remains after netting, the applicable benchmark rate is LIBOR plus 200 basis points rather than LIBOR plus 450 basis points.

An unregistered allotment letter may constitute an agreement fixing consideration for the first proviso to section 56(2)(x) where consideration is paid through prescribed banking modes on or before the agreement. The proviso protects genuine property transactions in which consideration was fixed before registration but stamp duty value later increased; it does not require registration of the agreement. Requirements for registration to transfer title are distinct from determining when contractual consideration was agreed. However, entitlement depends on verifying the flat's identification, allotment, payment linkage, agreed consideration and applicable stamp duty valuation.