Interest earned by a cooperative credit society on fixed deposits with a cooperative bank qualifies for deduction under Section 80P(2)(d), as the exclusion for specified cooperative banks does not deny the investing society's deduction. Under Section 57(iii), audit fees, employee welfare expenditure and common administrative expenses with a direct nexus to income earning are deductible, but gifts to retiring members and Covid-19 donations are not. Depreciation against income from other sources is unavailable unless the income falls within specified Section 56(2) categories. The society's final income must be taxed at the applicable cooperative-society slab rates rather than a flat rate.

Unaccounted sales evidenced by seized accounting data were treated as warranting an addition limited to the estimated profit element rather than the full receipts, because the material also indicated unrecorded purchases. Without an item-wise stock register or correlation between unaccounted sales and purchases, a lower profit estimate was considered inadequate. The possibility that costs of some stock had already been recorded while related sales were omitted supported estimating profit at 8% of unaccounted sales or receipts.

Addition of claimed onion-sale receipts as unexplained money requires examination of the assessee's supporting evidence. The material referred to includes an onion-seed purchase bill, cultivation expenditure details, sale bills, bank records showing receipt of sale proceeds, and claimed updated RTC particulars. As the relevant evidence and updated land-record entries had not been examined, detailed verification was considered necessary. The addition was set aside and the issue restored to the Assessing Officer for fresh verification and de novo adjudication, without a merits determination of the claimed income.

Eligible commercial vehicles qualified for higher depreciation under the applicable schedule, and a scientifically computed, consistently applied warranty provision linked to sales constituted a present business liability deductible in computing income. Research and development expenditure under section 35(2AB) required limited verification of the difference between DSIR-approved and claimed expenditure before allowance under the earlier precedent. Section 14A read with Rule 8D could not disallow expenditure for investments producing no exempt income; sufficient interest-free funds supported the presumption that income-yielding investments were funded from those sources. Deduction under section 80JJAA remained allowable consistently with earlier years.

Foreign tax credit is available to a resident partnership firm for overseas taxes withheld from professional receipts included in its taxable income in India, where prescribed documentation, including Form 67 and authenticated withholding certificates, is furnished. Under the Indo-Japan treaty, the independent personal services provision did not apply to the partnership firm in the relevant context and did not exclude its services from fees for technical services treatment. Section 90 and Section 90A of the Income-tax Act, read with Rule 128, therefore did not support denial of credit where treaty-based withholding was not shown to be erroneous.

Rejection of books under Section 145(3) requires material showing that accounts are incorrect or incomplete. Non-maintenance of quality-wise diamond stock particulars alone does not establish unreliability where audited books, inventory records, purchase and sales registers, vouchers and stock valuations are maintained, no specific defects or unrecorded transactions are identified, and the accounting method has been consistently accepted. A net-profit estimate must rest on a rational and scientific basis; an unsupported 3% estimation is unsustainable. The addition based on book rejection and estimated profit was deleted.

Interest for failure to deduct tax at source was examined where Form 26A certified that the recipient had included the relevant payments in income, filed its return, and paid the tax due. Where the recipient has discharged its tax liability, the deductor cannot face recovery of the underlying tax demand; any interest is limited to the period ending when the recipient pays the tax. On the available material, interest under sections 201(1) and 201(1A) was not sustainable and was set aside.

Section 56(2)(x) addition based on the difference between purchase consideration and stamp duty value requires consideration of the taxpayer's objection to the stamp duty valuation and request for reference to the District Valuation Officer. Where a Registered Valuer's report supports the stated purchase consideration, revenue authorities must address that valuation material. Finalising the assessment without considering the objection or making the requested valuation reference is unjustified. Fresh determination must be made in accordance with law after addressing the valuation dispute.

Revision under section 263 cannot be invoked merely because the revisional authority prefers a different view on ESOP/ESAR expenditure. Where the Assessing Officer sought detailed information, considered the taxpayer's explanation and applicable judicial position, and allowed the deduction, the assessment is not erroneous for lack of enquiry or non-application of mind. Acceptance of an SLP against a supporting decision does not make that decision ineffective without a stay or reversal. A direction for fresh verification based solely on a pending Supreme Court issue constitutes an impermissible change of opinion. The stated outcome was that the revisional order was quashed and the original assessment restored.

Cash deposits substantially linked to disclosed turnover from a genuine medical business should be treated as business receipts rather than wholly as unexplained money where licences, VAT/GST records, books, purchase and sale documents, and financial statements support the business and no defect is found in reported sales or VAT returns. The gross deposits cannot be assessed without recognising the expenditure and profit element inherent in trading receipts. Based on the nature of the trade and comparable profit ratios, profit was considered assessable at 5% of the deposits, subject to the applicable basic exemption limit.

Revision under Section 263 is confined, where an assessment is under appeal, to matters not considered and decided in that appeal; purchase disallowances and the estimated profit element already challenged before the first appellate authority fall outside that jurisdiction. Revision also cannot replace an Assessing Officer's legally plausible view where invoices, ledgers, transport records, payment details, confirmations and GST material were examined before estimating profit on disputed purchases. Non-genuineness of a supplier alone does not establish remission or cessation of an outstanding trading liability. Taxation of that balance requires material showing write-back, waiver, remission or cessation during the relevant year.

Revisionary jurisdiction cannot require initiation of penalty for under-reporting where the assessment retains the returned income and the disputed tax credit was already included in disclosed turnover. As no under-reporting arose, the statutory penalty computation mechanism did not apply. Initiation of such penalty proceedings depends on the Assessing Officer's satisfaction and remains discretionary rather than mandatory. Accordingly, failure to initiate penalty did not render the assessment order erroneous and prejudicial to Revenue, and the revisionary direction was unsustainable.

Settlement orders conclusively determine the matters covered by them and are not subject to writ interference merely because the Department disputes the Settlement Commission's appreciation of oral or documentary evidence. Judicial review is confined to procedural illegality, breach of natural justice, or action contrary to statutory provisions. Where no such defect is alleged and the challenge concerns only alleged unaccounted transactions and evidentiary appreciation, the settlement order remains immune from writ review.

Section 151A requires algorithm-based random allocation for assessment and reassessment under the faceless statutory framework. A Jurisdictional Assessing Officer cannot validly issue a reassessment notice under Section 148 outside that allocation regime, and administrative instructions cannot override or dilute this statutory requirement. Reassessment notices issued contrary to the faceless allocation framework, together with consequential orders, are without jurisdiction and liable to be quashed.

Procedural delay in uploading Form 10CCB and filing the income-tax return should not by itself defeat a Section 80IA deduction where the audit report was prepared within time and the delay resulted from the Chartered Accountant's admitted oversight. The failure to upload the report is treated as a technical irregularity, while the claimant's substantive eligibility for the statutory deduction requires examination on merits. Rejection of condonation is therefore unsustainable where the filing delay is marginal and no assessment of entitlement has occurred; the Section 80IA claim should be considered on merits without denial solely for delayed filing.

Reassessment limitation under the substituted regime is examined where alleged escaped income exceeded the threshold for the extended period under the erstwhile regime. A notice issued within the surviving six-year period is treated through the statutory legal fiction as leading to proceedings under Section 148A(b). The time allowed for the taxpayer's reply and completion of the statutory process is excluded when computing limitation for the Section 148A(d) order and consequential Section 148 notice. The stated concession for the relevant assessment year does not apply where escaped income exceeds the prescribed threshold.

A revision order under Section 263 concerning a post-demerger assessment was set aside because it was issued without adequate application of mind and before the audited post-demerger financial statements were prepared. The revised return required fresh consideration based on the relevant audited balance sheet and profit and loss account. The demerger's merits and the claimed capital-gains exemption were left open for independent determination. The matter was remitted for fresh adjudication after submission of a proper revised return founded on the audited post-demerger financial statements.

Project-specific Government grants subject to mandatory utilisation for a specified scheme are not treated as taxable income where the recipient does not have unrestricted entitlement to the funds. Interest payable on unutilised grant funds under the governing disbursement terms is an ascertained business liability and is deductible, rather than contingent. Under the block-of-assets regime, depreciation cannot be restricted by separately identifying assets retired from active use if business assets within the relevant block are used; simultaneous use of every individual asset is not required.

Sale of flats was characterised as giving rise to capital gains rather than business income because the flats were acquired, recorded and managed as investments, including efforts to lease them. The isolated project, substantial holding period, staggered sales, and lack of volume, frequency, continuity or regularity associated with real-estate trading supported investment intent. While accounting treatment was not conclusive, it remained relevant when considered with the overall conduct. Earlier acceptance of capital-gains treatment, without changed facts or incriminating material, also supported consistency. Whether a transaction is an adventure in the nature of trade depends on intention and the totality of circumstances, with the Revenue bearing the burden of proving trading character.

A special leave petition concerning the allowability of a provision for discount as an expense was not entertained by the SC in view of the peculiar facts and circumstances. The petition was dismissed, while any question of law was expressly kept open. The text does not state a binding determination on whether such discount provisions are allowable deductions.