Section 92CD(3) requires a pending assessment for a year covered by a unilateral advance pricing agreement to be completed in accordance with that agreement after considering the modified return. Where the modified return was filed during pending assessment proceedings and complies with the agreement, the original transfer-pricing adjustment cannot be retained merely because objections concerning covered transactions were withdrawn. The Assessing Officer and Transfer Pricing Officer must give effect to the agreement and modified return while completing the assessment.

For software development services, the employee-cost-to-sales filter applies within a 50%-80% range, requiring a fresh transfer-pricing computation. Companies lacking segmental data, those affected by extraordinary amalgamation, and entities performing programming or consultancy functions outside the relevant segment are excluded from the comparable set. Outstanding trade receivables are international transactions, but an interest adjustment cannot stand where the Comparable Uncontrolled Price method lacks segmental comparable evidence or supporting trends. Working-capital effects on pricing and profitability require fresh examination when determining the arm's length price. The resulting determination uses the revised filter and comparable set, deletes the receivables-interest adjustment, and reconsiders the working-capital adjustment.

Registration under sections 12AB and 80G(5) should not be rejected solely because charitable activities had not commenced when applications were filed where subsequent activity occurred during their pendency and requires verification to assess genuineness. Delay-condonation explanations submitted with Form 10AB require consideration, including available measures under section 119(2)(b). An activity note may satisfy the need for activity-related information, and Darpan registration is not identified as a statutory condition for either registration or approval. A fresh, speaking determination after due verification and a reasonable opportunity of hearing is required.

Possession of land granted to a developer solely to construct residential flats under a development agreement does not constitute a transfer for capital-gains purposes where it is only a development licence. Part performance requires possession under the contract and performance, or willingness to perform, contractual obligations. Without possession of that character, capital-gains charging provisions do not apply, and the related long-term capital-gains addition is deleted.

Section 144C(13) requires a final assessment to be completed within one month from the end of the month in which Dispute Resolution Panel directions are received. In a faceless process, receipt occurs when the directions are uploaded to the designated portal; subsequent internal transmission or later availability to the Assessing Officer does not extend that statutory period. Directions uploaded on 30 December 2025 therefore required completion by 31 January 2026. A final assessment order dated 19 February 2026 was consequently treated as time-barred and void.

Section 69A requires a satisfactory explanation of the nature and source of cash or jewellery found. Disclosed and unrebutted opening cash balances supported by returns and financial records may establish the source where they exceed the cash found; cash is fungible, so physical continuity or identity of currency notes need not be shown. Family wealth-tax disclosures and documented bullion purchases may similarly establish aggregate jewellery availability. Once documented availability exceeds the quantity found, the burden shifts to the Revenue to establish disposal of disclosed assets or an undisclosed acquisition. Conjecture, household-expense assumptions, and item-wise matching demands cannot replace evidence.

Assessment under section 143(3) must be made in the name of an assessee that exists when the order is passed. Where a partnership firm converts into a private limited company and the Assessing Officer is informed before assessment, the firm ceases to be an assessable entity. An assessment subsequently issued in the former firm's name is void because settled principles prohibit assessment of a non-existent entity. The resulting assessment order is liable to be quashed.

Service-tax turnover and income-tax revenue may differ in real-estate projects because service tax applied to advances received, while income under the mercantile system and Percentage of Completion Method is recognised at the relevant stage of project completion. Customer advances remain liabilities until then. Where audited books, financial statements and project-wise workings support recognised revenue, no accounting discrepancy is shown and the books are not rejected, the mismatch is a timing and accounting-basis difference. It cannot be treated as unaccounted turnover or taxable income, supporting deletion of the addition.

Section 271AAB requires undisclosed income to be represented by money, bullion, jewellery, another valuable article or thing, or an entry, document or transaction found during a search. A stock shortage identified by comparing physical inventory with book stock is an absence, not search material. Where alleged unrecorded sales are inferred solely from that shortage and gross profit is estimated without evidence of outside-the-books sales or false expense entries, the estimated profit does not satisfy the statutory definition of undisclosed income. Penalty proceedings remain independent of assessment proceedings, and acceptance of an addition is not conclusive. Strict construction places the burden on the Revenue to establish all statutory conditions; penalty is therefore unsustainable.

Registration eligibility under section 12A(1)(ac)(vi), reflected in section code 4A, depends on whether income was actually excluded from total income under sections 11, 12 or specified section 10(23C) provisions. Filing Form ITR-7 alone is not conclusive evidence that those exemptions were claimed or availed. An application should not be treated as non-maintainable solely because that return form was used; the returns, schedules, computations, and processing or assessment records require examination.

Section 69 requires an investment addition to rest on an unexplained or unsatisfactorily explained source. Verified bank payments and housing-loan financing may establish the source of payments for jointly acquired property, and another co-owner's contribution cannot be treated as one purchaser's unexplained investment. For stamp-duty valuation purposes, documented additional consideration must be included in the actual aggregate consideration before determining any difference. In a joint purchase, only the amount attributable to the relevant co-owner may be assessed; the entire difference cannot be brought to tax in one co-purchaser's hands, particularly where that share falls below the statutory threshold.

Binding CBDT Instruction No. 1/2011 allocated assessment jurisdiction over a non-corporate taxpayer reporting income above the prescribed threshold to an Assistant or Deputy Commissioner, not an Income-tax Officer. Reassessment initiated, noticed and completed by an Income-tax Officer despite that allocation was treated as void for inherent lack of pecuniary jurisdiction. The unsecured-loan addition remained deleted because remand verification disclosed no adverse finding and Revenue produced no contrary evidence, legal error or factual infirmity; characterising the remand report as a draft did not displace the appellate findings.

Additional evidence consisting of a Departmental Valuation Officer's report on the fair market value of jointly purchased property is relevant to an addition for the difference between purchase consideration and stamp duty value under section 56(2)(x). Where the report directly bears on that valuation difference and requires verification at the assessment stage, the evidence may be admitted and the addition remitted to the Assessing Officer for verification and fresh adjudication after a reasonable hearing opportunity. All contentions on the merits remain open.

Reassessment initiated more than three years after the end of the relevant assessment year requires approval from the specifically designated higher authority under the applicable sanction provision. Approval by the Principal Commissioner did not satisfy that mandatory jurisdictional requirement. Treating an earlier notice under the former reassessment regime as deemed proceedings under the new procedure did not remove the requirement of competent approval for the consequential reassessment notice. The reassessment notice was therefore invalid, and the consequential reassessment, assessment and cash-credit addition were set aside.

Condonation of delay may be supported by COVID-19 disruption and the overseas location of key decision-makers where the explanation shows no mala fides. Transfer-pricing comparability requires reliable relevant-year financial and functional information, material functional similarity, and satisfaction of applied quantitative filters. Companies without verifiable public data, performing highly technical infrastructure-project services involving brand intangibles, carrying out government-driven diversified activities, or failing the employee-cost filter are excluded from the comparable set. The arm's length price determination excludes the four challenged comparables.

Section 68 does not permit an admitted advance received in financial year 2006-07 to be assessed as an unexplained cash credit in assessment year 2016-17. A subsequent land-sale transaction allegedly structured to obtain a capital-loss set-off may indicate tax avoidance, but cannot alter the year in which the advance was received or became taxable. Any alleged avoidance must be addressed through other applicable statutory measures rather than by treating the historic advance as a fresh unexplained cash credit.

An approved insolvency resolution plan that expressly bars tax claims for a pre-effective-date period binds revenue authorities, extinguishing unpreserved claims and precluding reassessment or revision for that period. The Insolvency and Bankruptcy Code's moratorium and overriding effect support that result. Separately, reassessment requires the prescribed preliminary inquiry, independent application of mind, disclosure of third-party material to permit a meaningful response, and compliance with limitation. Initiation founded only on external reports, without inquiry or disclosure, and beyond limitation is without jurisdiction. These requirements prevent reassessment claims that conflict with binding resolution-plan terms.

Acceptance of an alternative concession before the Tribunal barred the assessee from challenging the resulting disallowance of agricultural loss relating to saplings. Where the Tribunal had acted on the assessee's own alternative submission, the assessee could not maintain an appeal against that part of the order. The High Court therefore declined the proposed questions and dismissed the appeals.

Section 14A disallowance computed under Rule 8D for expenditure relating to exempt income is not a permitted adjustment to book profit for minimum alternate tax under Section 115JB. Binding jurisdictional decisions establish that the statutory computation disallowance cannot be added back while determining book profit, and the Revenue accepted that the issue was covered by this settled position. The question was therefore resolved in favour of the assessee.

Service of statutory reassessment communications through a secondary email address and at a former residential address did not afford the assessee an effective opportunity to respond to the notice under section 148A(b). As those modes of service were undisputed, sufficient cause existed to permit a response while leaving the merits for determination by the assessing authority. The reassessment and consequential proceedings were set aside, and the assessee was permitted to submit a response to the notice.