Under the post-1 April 2021 reassessment regime, prior approval for a reassessment notice depends on the time elapsed from the end of the relevant assessment year. Once more than three years have elapsed, Section 151 requires sanction from the prescribed higher specified authority rather than a Principal Commissioner. Approval by an authority lacking that prescribed competence renders the reassessment notice invalid and undermines the consequential reassessment proceedings.

Estimated chit subscriptions cannot be treated as unexplained investment under Section 69 merely by averaging aggregate chit dealings across years. Where impounded material records liabilities rather than a specific unrecorded investment in the relevant year, and bid receipts and borrowings explain instalment funding, the addition is unsustainable. Likewise, estimated interest cannot be assessed as unexplained expenditure under Section 69C through mathematical allocation of an aggregate amount without year-specific evidence of actual payment. Continuing borrowings and upfront interest deductions from loan disbursements provide an identifiable source. Broad admissions without transaction-specific corroboration cannot alone sustain such additions.

For capital introduced by a partner, the firm established the contributor's identity, capacity and the genuineness of the remittances through recorded direct transfers, payments to land vendors, a registered sale deed and assessment of the sale consideration as capital gains in the partner's own case. The capital computation also required exclusion of opening capital, credited profit and remuneration. Where the partner admits and substantiates the contribution, a separate question concerning the partner's source does not, on the established facts, justify treating the amount as unexplained cash credit in the firm's hands.

Tax-deduction disallowance of residual consultancy charges remained sustainable because the supporting material did not show that the amount fell outside the withholding obligation, while substantiated service-tax relief was retained. Interest disallowance was sustained for one payee lacking compliance evidence and remitted for verification for another payee. Expenses crystallising during the relevant year, including invoices issued to an affiliated entity on identical facts, were treated as allowable; prior-period treatment was revenue neutral. Written-off balances, though not allowable as bad debts, qualified as business expenditure or business loss. Customer advances were not unexplained cash credits where identity, genuineness and creditworthiness were established. No disallowance under section 14A and rule 8D applied absent exempt income; deletions of prior-period and business electricity expenses were retained.

Reassessment notices for assessment years 2013-14 and 2014-15 were issued after the applicable limitation period expired. After accounting for the surviving limitation period and the statutory minimum period following the assessee's response to show-cause notices, the deadline ended on 16 June 2022. Notices issued under Section 148 in late July 2022 were therefore time-barred. The amended reassessment regime and relaxation legislation did not preserve the Revenue's authority to issue notices after expiry of that limitation. Consequently, the reassessment proceedings based on those notices were void and quashed.

Reassessment under Section 147 requires recorded reasons based on tangible material identifying the alleged accommodation-entry entities and transactions. General information, unsupported by credible material, cannot justify reopening where statutory notices, approval material and the assessment order omit the relevant entities. Bank records and audited financial statements showing no transactions, borrowings or repayments with those entities further negate the alleged basis for reassessment. The reassessment proceedings and consequential assessment were therefore void ab initio and quashed.

Income recognised on accrual basis for completed consultancy services cannot be taxed again merely because the related tax deduction appears in Form 26AS in a later year; the timing of tax deduction does not override income recognition. Transfer charges and commission directly connected with sale of property are deductible when computing capital gains, even if not allowable as business expenditure. Professional fees for arranging working-capital funding require adequate proof of business utility and substantiation; where these are incomplete, proportionate disallowance may apply. The discussion treats the Form 26AS mismatch addition as unsustainable, allows property-transfer expenses under capital gains, and supports partial disallowance of inadequately supported funding consultancy fees.

Business-promotion expenses were treated as business-related but only partly substantiated, resulting in restricted disallowance. Letter-of-credit charges and software-development expenditure were treated as allowable because partial capitalisation lacked a sustainable basis and a one-time payment alone did not establish capital character. Foreign-exchange loss, fixed-deposit interest additions, unsupported expenditure, gratuity provision and tax-payment claims remained disallowed for lack of reconciliations, accounts, supporting particulars or proof of payment. Ad hoc disallowances for engineering stores and printing and stationery were reduced as the original rate was excessive. Taxable income requires recomputation after giving effect to deleted, restricted and sustained disallowances.

A notice under Section 148 for Assessment Year 2015-16 was beyond the limitation period applicable under the pre-amendment regime, which expired on 31 March 2022. The first proviso to Section 149(1), inserted by the Finance Act, 2021, preserves that restriction for past assessment years. The fifth and sixth provisos, which provide exclusion and extension mechanisms within the amended three-year or ten-year framework, cannot extend the limitation preserved by the first proviso. Consequently, the notice dated 7 April 2022 was time-barred, invalid, and incapable of conferring jurisdiction for reassessment.

Revisionary jurisdiction under section 263 cannot be invoked merely because the Assessing Officer could have conducted further or more extensive enquiries. Specific notices, explanations, books, bank records, confirmations, invoices, e-way bills, GST records and affidavits were examined, and additions were made after considering seized material. A finding that an assessment is erroneous and unsustainable requires support from the assessment record or an independent enquiry. The revision proceedings also overlooked a rectification order enhancing the accommodation-entry addition and did not examine the record of prior assessment approval. The section 263 order was therefore quashed.

Corporate social responsibility donations to institutions approved under section 80G remain deductible under that provision where no express exclusion applies, despite their non-deductibility as business expenditure under Explanation 2 to section 37(1). Denial solely because the payments discharge mandatory CSR obligations would create an unintended double disallowance. Interest under section 234C requires verification and recomputation of advance-tax liability. Interest on refunds under section 244A requires verification of relevant dates, including refund issuance, with additional interest to be granted if legally due.

Notice for assessment under the Black Money Act was issued beyond the timeline prescribed by CBDT Guidelines. Information on the undisclosed foreign asset was available to the Department in April 2019 and, at the latest, when reopening reasons were recorded in March 2021. The Guidelines required a section 10(1) notice preferably within 30 days after the relevant previous year, with written reasons and competent-authority approval for delay. No recorded reasons or approval supported the delayed March 2022 notice. As the administrative instructions bound the Revenue, the notice was time-barred and consequential proceedings were null and void.

Scientifically estimated warranty provisions based on historical trends are described as deductible trading expenditure under Section 37(1), where sale creates a present contractual obligation and expected costs are matched with recognised revenue. Withholding tax contractually borne by an assessee on a net-of-tax royalty payment is treated as part of the royalty consideration and allowable business expenditure. For in-house scientific research, Section 35(2AB) is described as requiring DSIR approval of the research facility, not certification of the expenditure amount; qualifying expenditure, excluding land or building costs, should therefore not be restricted to DSIR-quantified amounts. Consequential interest is stated to require recomputation.

For assessments under section 153C, where the Assessing Officer of the searched person and the other person is the same, transfer of the other person's case and seized material to that officer is treated as the relevant handing-over date. Where records were transferred under section 127 before the satisfaction note was recorded, limitation runs from the transfer order, not from the later satisfaction note. On the stated facts, the assessments were treated as time-barred and quashed.

Delayed furnishing of Form 67 is treated as a procedural, technical and venial lapse and does not by itself justify denial of an otherwise admissible foreign tax credit. Where the income-tax return was filed within time and Form 67 was uploaded before the rectification application was considered, the delay may be condoned. The foreign tax credit remains subject to verification and grant in accordance with law.

Writ proceedings concerning reassessment notices were remitted for fresh consideration in light of a subsequent statutory amendment and Supreme Court directions. The writ appeal was allowed, the single judge's order was set aside, and the writ petition was restored for reconsideration. Liberty was reserved to challenge Section 147A of the Income-tax Act.

Reassessment notices issued solely on the basis of the Shah Commission report concerning illegal mining were treated as unsustainable where a coordinate-bench ruling in a similar factual setting, applying relevant High Court precedent, supported the assessees' challenge. The reassessment notices and all consequential proceedings were quashed in favour of the assessees.

Loans or advances received by a public trust from a company in which its managing trustee held substantial shareholding cannot be treated as deemed dividend under Section 2(22)(e) on the stated facts. The provision extends the meaning of dividend but does not treat a non-shareholder recipient as a shareholder, and a public trust is not among the specified concerns in Explanation 3. In the absence of evidence that the trust was a conduit for the trustee's individual benefit, the deeming provision does not apply. Reassessment proceedings based on that premise were therefore invalid.

Deletion of the disallowance of loss on sale of shares did not raise a substantial question of law where similar transactions for the preceding assessment year had been accepted as genuine on documentary evidence. As no contrary material was produced to displace that evidence, the same reasoning applied for the relevant year. The Gujarat HC noted that the Tribunal's earlier decision had already been confirmed and that the issue was decided in favour of the assessee.

Trade-promotion activities of an association representing mandap contractors can advance an object of general public utility where its dominant purpose is to organise events, share knowledge, educate members, encourage the trade and represent collective interests, rather than profit-making. Incidental benefits to members do not negate charitable character. For registration under Section 12AA, the prescribed documents may establish the creation or establishment of a trust or institution; separate registration with the Registrar of Companies, Firms and Societies, or Public Trusts is not an absolute precondition. The rejection of registration on these grounds was unsustainable and required fresh consideration under law.