Rectification under section 254(2) is confined to mistakes apparent from the record and cannot reopen a reasoned merits determination merely because a deduction under section 10A is alleged to have been wrongly denied or an inapplicable precedent was not followed. The request to recall or modify the merits finding on the deduction was therefore rejected. However, failure to adjudicate raised alternative grounds concerning foreign-exchange gain in total turnover and net hedging gain constituted an apparent omission. The order was consequently recalled only to the limited extent necessary to decide those omitted grounds, while the merits determination remained undisturbed.

Interest or dividend income received by a co-operative society from another co-operative society or co-operative bank qualifies for deduction under section 80P(2)(d). Co-operative banks are treated as co-operative societies for this deduction, and the stated Tribunal approach, supported by High Court decisions, recognises eligibility where no contrary facts or legal position apply. The deduction therefore extends to interest income earned from co-operative banks.

Section 44 provides a specific and overriding regime for computing profits of an insurance business. Accordingly, section 14A read with rule 8D does not apply to a life insurance company whose profits are computed under section 44. Earlier decisions on the same position were followed, with no material identified to justify a different approach. The resulting effect is that expenditure disallowance under section 14A and rule 8D is excluded for the life insurance business, and the disallowance is deleted.

TDS credit denied because of a Form 26AS mismatch cannot result in a duplicate addition where the corresponding gross interest income has already been offered to tax, subject to verification that tax was deducted at source and the taxpayer's evidence substantiates the claim. The adjustment should then be deleted, notwithstanding the deductors' failure to deposit the TDS. Interest on refunds under Section 244A is payable up to the date the refund is actually issued or received, rather than an earlier computation date, and must be recalculated accordingly.

Uncontroverted medical treatment and bereavement may constitute sufficient cause for condoning a delayed appeal where no deliberate or mala fide delay is shown, allowing substantial justice to prevail over technical considerations. Short-term capital gains from jointly owned developed property require verification of the taxpayer's ownership share, capital contribution, share of sale consideration, and substantiated construction expenditure. An assumed withdrawal under a dispute-resolution scheme does not resolve those factual claims. Taxable gains therefore require fresh determination after examination of supporting evidence and an adequate opportunity of hearing.

Delayed property registration does not by itself trigger taxation of the difference between agreed consideration and stamp-duty value where the purchase agreement, payment and transfer evidence predate a subsequent amendment to Section 56(2)(vii)(b). A later-introduced provision cannot govern an earlier completed transaction merely because registration occurs later. An addition for unexplained stamp-duty and registration expenditure is unsustainable where bank records show fixed-deposit closure and transfer of funds for the payment, and no contrary evidence rebuts that disclosed source. The stated principles support deletion of additions based on later stamp-duty valuation and allegedly unexplained expenditure.

Profit on redemption of debentures, already offered as short-term capital gains, may not also be assessed as income from other sources unless an express statutory provision permits double taxation. Processing under section 143(1) treated the amount as income from other sources after reducing it from business receipts. Verification of the return computation and supporting evidence was required to determine whether the same income had been taxed twice. The double-taxation claim was restored to the Assessing Officer for limited verification and adjudication on merits.

Deduction under section 80P could not be disallowed through an adjustment under section 143(1)(a) where processing occurred before 1 April 2021. The power under section 143(1)(a)(v) to disallow Chapter VI-A deductions became effective only from that date; consequently, the Centralized Processing Centre lacked authority to make the adjustment during processing in 2019. The section 80P disallowance was therefore invalid, and the claimed deduction was required to be allowed.

Cash deposits explained through business cash sales and opening cash balance, but unsupported by sufficient material, may be subjected to a reasonable estimated addition rather than being wholly treated as unexplained money. Under the stated approach, taxability was confined to 30% of the deposits and the remaining addition was deleted. The enhanced tax rate under section 115BBE was inapplicable for assessment year 2017-18, based on consistent Tribunal decisions. Consequently, only the estimated portion of the deposits remained taxable without the enhanced rate.

Penalty for under-reporting of income cannot survive where the additions forming its basis have been deleted in the corresponding quantum proceedings. Additions relating to differences in the capital account and sundry creditors were deleted for the same assessment year, eliminating the factual foundation for the penalty. The penalty was therefore unsustainable and liable to be cancelled.

Search-related penalty under section 271AAB displaces section 271(1)(c) only for undisclosed income of a statutorily defined specified previous year. Where a search occurred on 04.02.2016, only assessment year 2016-17 qualified; penalty under section 271(1)(c) for that year was void, while section 271(1)(c) remained potentially applicable to earlier years. For assessment years 2010-11 to 2015-16, additions of deemed annual letting value based on disallowed vacancy allowance could not support penalty where property details and actual rent were fully disclosed. Rejection of a claim, without false, incorrect, or incomplete particulars, does not establish concealment or furnishing inaccurate particulars. Penalties for all years were therefore unsustainable.

Loss arising from market-value fluctuation of securities classified as Available for Sale and held in the course of banking business is allowable as a revenue loss. Securities acquired under banking norms require valuation at market price, and the difference between book value and market value arises in the ordinary course of that business. Accordingly, the valuation loss is deductible as a revenue loss and the disallowance is deleted.

Late-filing fee under section 234E could not be computed while processing TDS statements under section 200A for periods before 1 June 2015. The amendment expressly enabling such computation under section 200A operated prospectively from that date. Where no jurisdictional High Court ruling existed and High Courts had adopted divergent interpretations, the construction favourable to the assessee applied. Consequently, late-filing fee levied through pre-amendment section 200A processing, along with the consequential demand, was liable to be deleted.

Cash deposits recorded in regularly maintained and audited books, supported by cash-book entries and corresponding VAT-return sales, were not treated as wholly unexplained where no defect in the books was identified and the books were not rejected. Statistical comparison showing abnormal cash-sales trends against an earlier period alone did not support the full proposed addition. Possible revenue leakage was addressed through a lump-sum addition, restricted to Rs. 5 lakh and taxable as normal business income.

Customer advances relating to completed real-estate projects should not be taxed again where revenue was consistently recognised on execution of sale deeds and had already been offered to tax in earlier years. Section 43CB, effective from 1 April 2017, does not apply to projects commenced before 2011. Subject to verification that revenue from the relevant projects was previously taxed, adding outstanding customer advances would constitute impermissible double taxation and the addition should be deleted.

Unsecured loans from identified corporate lenders were satisfactorily explained under Section 68 where confirmations, tax returns, bank statements, ledger extracts and audited financial statements established identity, creditworthiness and genuineness. Banking-channel transactions without cash deposits, coupled with no material linking the loans to the assessee's unaccounted funds, shifted the burden to the Assessing Officer; suspicion, alleged accommodation entries or lack of business activity could not sustain additions. The assessee need not prove the source of the source. Share-sale receipts from directors were likewise explained through documented fund flow from an identified company and were not liable to addition as unexplained cash credits.

Charitable trusts that held earlier exemption and timely sought fresh registration under the new registration regime within the extended CBDT deadline remain eligible for exemption for the relevant assessment year. Where registration is granted after the application is found in order, making the certificate operative only from the succeeding year would create an anomalous gap between exempt earlier and later years. Registration should therefore operate from the relevant assessment year, requiring allowance of exemption and deduction under Section 11.

Charitable trusts registered under section 12AA may claim exemption under section 11 where the return is validly filed within the time permitted by section 139, including a belated return filed under section 139(4). The CBDT clarification treats the expression "within the time allowed under section 139" as broader than the due date for filing under section 139(1). On materially similar facts, the claimed section 11 exemption was required to be allowed for AY 2018-19.

Securities held by a banking institution as stock-in-trade do not attract disallowance of expenditure relating to exempt income in the stated circumstances. Tax deducted at source credit on recoveries from auction sale of defaulting borrowers' properties remains available where the related interest and other recoveries are offered to tax, even if the balance sale proceeds are credited to borrowers' accounts. Brought-forward long-term capital losses may be carried forward where preceding scrutiny assessments allowed those losses and contain no specific disallowance. The expenditure disallowance, denial of tax credit, and denial of loss carry-forward were therefore not sustainable.

Third-party seized documents cannot alone support additions where no statement from their possessor establishes their nature, authorship or contents, departmental inquiry yields no adverse material, and no independent corroboration links them to the assessee; the additions are unsustainable. Statutory approval for assessment must reflect independent application of mind to each assessment year. A single omnibus approval covering multiple years, issued mechanically, fails that requirement and vitiates the assessment. Consequently, assessments based on both defective consolidated approval and unsupported third-party material cannot be sustained.