Omission of Section 92BA(i) by the Finance Act, 2017, without a saving provision, removes the legal basis for transfer-pricing proceedings concerning specified domestic transactions initiated solely under that clause. Applying the principle that an omitted provision is treated as never having existed, a reference to the Transfer Pricing Officer under Section 92CA(1) founded on Section 92BA(i) lacks legal sustainability. Consequential transfer-pricing and Dispute Resolution Panel proceedings based on that reference are likewise invalid.

Reassessment requires reasons recorded before notice issuance under section 148(2), authenticated in accordance with section 282A and Rule 127A. Where the purported recorded reasons lack the Assessing Officer's name, designation, seal and signature, they are not duly authenticated. A Joint Commissioner's signed approval under section 151 cannot cure or substitute for authenticated reasons recorded by the Assessing Officer. Consequently, the reassessment notice and resulting assessment are void from inception, and the assessment order is quashed.

Cash deposits were explained through maintained cash books showing opening and accumulated balances; presumptive-tax returns did not require the detailed balance-sheet disclosures relied upon by the tax authorities, so no unexplained-money addition was sustainable. Agricultural land supported by official certification and verification as lying beyond the prescribed municipal limit was not a capital asset, making sale profit exempt rather than taxable as short-term capital gain. Bank credits substantiated by sale deeds, bank records, ledgers, confirmations and tax records represented sale consideration and advance repayments, not business turnover; profit estimation on those credits was therefore unsustainable. The disputed additions were deleted.

Unsecured loans supported by lender confirmations, PAN details, income-tax returns, financial statements, bank statements and loan agreements satisfy the taxpayer's primary burden on identity, creditworthiness and transaction genuineness. Receipt and repayment of loans with interest through banking channels further support the transactions. General information or suspicion that a lender may provide accommodation entries cannot, without credible material directly connecting the loans to such entries or disproving the evidence, justify unexplained cash-credit additions. The cash-credit additions were therefore unsustainable, and consequential additions for alleged commission and bogus interest expenditure could not survive.

Penalty under Section 271D for contravention of Section 269SS cannot subsist where the assessment order containing the Assessing Officer's recorded satisfaction to initiate penalty proceedings has been quashed. The corresponding principle applicable to Section 271E applies because Sections 271D and 271E are pari materia. Independently, where satisfaction and penalty initiation occur in the assessment order, the limitation period under Section 275(1)(c) runs from that initiation, not from a later notice or action by the competent penalty authority. The penalty was therefore unsustainable on both its invalid foundation and limitation.

Enhanced penalty for misreporting of income requires identification of the specific statutory instance of misreporting under section 270A(9). Section 270A distinguishes ordinary under-reporting from under-reporting resulting from misreporting, for which the enhanced penalty under section 270A(8) applies only where one of the listed instances is established. Where assessment-stage satisfaction referred to under-reporting due to misreporting but the notice and penalty order alleged misreporting without specifying the applicable statutory limb, the charge was defective. The failure to specify the precise misreporting instance vitiated the penalty proceedings and could not be cured.

Reasonable cause supported by bank records, affidavits and revenue records can protect cash receipts and repayments from penalties for contravening statutory restrictions. Cash received from farmers for a proposed agricultural-land purchase, followed by cash repayment after the transaction failed because of the taxpayer's father's death, was sufficiently explained by the surrounding circumstances and documentary evidence. The penalties for accepting and repaying cash loans were therefore deleted, as the established reasonable cause negated penal consequences.

Reassessment based on search information together with enquiry into an entry-provider and related transactions may proceed under reassessment provisions where the recorded information supports that route and the prescribed approval is properly obtained; the reassessment was sustained. Where corresponding sales are accepted but purchases from an entry-provider remain unsubstantiated, the entire purchase value should not be disallowed. The taxable addition is confined to a reasonable estimate of the profit element embedded in those purchases, quantified at 6% based on the gross-profit position and other material, including a retracted statement.

For reassessment notices issued after four years from the end of the relevant assessment year, Section 151(1) requires prior sanction from the Principal Chief Commissioner, Chief Commissioner, Principal Commissioner or Commissioner. Approval obtained only from an Additional Commissioner does not satisfy this mandatory jurisdictional requirement. Consequently, a reassessment notice issued for assessment year 2015-16 after the four-year period on the basis of such approval was invalid, and the resulting reassessment order was vitiated.

An assessee-bank that made foreign-travel LFC/LTC payments while a High Court interim direction prohibited tax deduction at source could not be treated as an assessee in default. The operative direction treated such payments or reimbursements as non-income for TDS purposes and placed any eventual tax liability on employees if the writ petition failed. Compliance was binding on the bank, while contrary deduction could have exposed it to contempt. Subsequent disposal of the writ proceedings did not retrospectively create a TDS default. Consequently, the tax demand and interest for non-deduction were inapplicable and liable to be cancelled.

Qualifying corporate social responsibility donations remain deductible under section 80G unless expressly excluded. Explanation 2 to section 37(1) only denies treatment of CSR expenditure as business expenditure and does not bar deductions under other provisions; the specific exclusion for contributions to Swachh Bharat Kosh and Clean Ganga Fund cannot be extended to other approved institutions. Mandatory CSR obligations do not remove the voluntary choice of a qualifying recipient. Dividend distribution tax on dividends paid to a United Kingdom holding company is limited to the 10% treaty rate under Article 11(2), and tax collected above that rate must be refunded, consistent with Article 265 of the Constitution.

Book profit under Section 115JB(2) may be adjusted only through the exhaustive additions and deductions specified in Explanation 1. A disallowance computed under Section 14A is not, by itself, a permitted addition to book profit. Similarly, expenditure disallowed under Section 35DD in relation to a demerger cannot be added back because Explanation 1 does not cover such disallowance. Minimum alternate tax computation therefore cannot be altered by importing disallowances outside the prescribed adjustments.

Section 14A(2) permits computation of expenditure relating to exempt income under Rule 8D only after the Assessing Officer examines the assessee's accounts and records dissatisfaction with the correctness of its claim or suo motu disallowance. A bare statement that the disallowance does not comply with Rule 8D, without identifying defects in the accounts or explaining why the claim is incorrect, does not meet this statutory precondition. Consequently, a Rule 8D disallowance made without recorded, account-based satisfaction is unsustainable and must be deleted.

Charitable registration under section 12AB cannot be refused merely because objects permit charging fees or because rent is paid to a trustee's spouse. Objects relating to public facilities, medical relief, poverty relief, education, skill development and public welfare remain charitable where profits cannot be privately distributed and activities are genuinely pursued. Food distribution, marriage assistance and Gau Seva supported genuineness; unverified concerns over related-party rent and residential use required examination rather than a finding of diversion. Section 80G approval could not be denied once section 12AB registration was due, and the Form 10AB application was timely under the extended filing deadline. Assessment authorities may examine ongoing statutory compliance.

Principles of natural justice require a meaningful opportunity to examine or cross-examine public officials whose inspection reports materially support an assessment on disputed facts. Reports concerning the physical character and cultivation of land were central to rejecting an explanation that transactions represented agricultural income; title-deed descriptions alone were not conclusive. Although cross-examination is not automatic in assessment proceedings, it is necessary where required for a fair hearing, and an appellate remedy does not bar writ relief when denial would cause loss of a forum. Fresh proceedings must also permit examination of witnesses produced on the requested extended date and allow further evidence.

Section 264 provides wide, beneficial revisional jurisdiction to relieve an assessee from over-assessment, including where the excess tax results from the assessee's own mistake or failure to claim relief in the return. Expiry of the period for filing a revised return under Section 139(5) does not bar revision where the same income has been taxed in two assessment years. Treating a disallowance in one year and its reversal in another as separate events cannot justify double taxation. Retention of tax not lawfully due contravenes Article 265. The Commissioner must examine reconciliations and the double-taxation claim on merits rather than mechanically reject revision by applying standards associated with Section 263.

Audited accounts of a foreign company undertaking a qualifying turnkey power project cannot be rejected merely because they show losses, work-in-progress, revenue-recognition issues or freight-cost variations, unless material defects are established. A satisfactorily explained loss, including one arising from increased ocean-freight costs, does not justify presumptive profit computation. For transfer pricing, a third-party contract price may constitute a reliable internal Comparable Uncontrolled Price where the Indian project office executes the contract, bears the relevant risks and rewards, and receives the full contract revenue. In those circumstances, the internal CUP method is preferable to TNMM, and no TNMM-based adjustment is warranted.

Discounted Cash Flow Method may support fair market value of shares issued by a newly incorporated company even before its later notification under Rule 11UA, where it was already a recognised valuation approach. Section 56(2)(viib) permits valuation by a prescribed method or another method substantiated to the Assessing Officer's satisfaction. Net Asset Value Method may not capture a newly incorporated company's commercial potential. Procedural prescription of valuation methods cannot displace substantive rights without substantial legal breach. The Assessing Officer may examine defects in the valuation report or methodology but should not substitute the valuer's commercial estimate of expected return with an independently selected rate.

Identity-theft objections to transaction information linked to a PAN do not, without conclusive enquiry, prevent reassessment proceedings under the amended framework. At the Section 148-A stage, the relevant question is whether the matter is fit for a Section 148 notice, and substantial transaction information is relevant material. A GST communication that does not conclusively determine identity theft cannot establish that the taxpayer did not undertake the transactions. The defence requires evidence and examination during reassessment. Once the taxpayer substantiates non-involvement, the Revenue must produce primary positive evidence that the taxpayer undertook the disputed transactions; disputed information alone does not shift that burden.

The statutory eighteen-month period for an Interim Board to decide a pending settlement application begins on its first allotment and receipt by that Board, not on a later administrative transfer. Under Sections 245D(4A)(iii), 245D(9)(iii) and 245M(2), prior exercise of jurisdiction, including calling for a Rule 9 report under the e-Settlement Scheme, establishes that allotment had occurred. An administrative movement of the file cannot restart or extend the prescribed period, since repeated transfers could otherwise indefinitely enlarge the deadline. The period is mandatory; orders passed after its expiry are time-barred, without jurisdiction and a nullity.