Penalty proceedings for undisclosed income found during a search require a notice under section 274 that identifies the precise charge under section 271AAB, including the applicable statutory clause and corresponding penalty rate. This specificity is necessary to provide a meaningful opportunity of hearing. A notice that merely refers generally to undisclosed income and proposed penalty under section 271AAB, without identifying the relevant conditions, is vague and invalid. Defective initiation notices invalidate consequential penalty proceedings; the penalty is deleted, leaving the substantive merits of the levy unexamined.

Revisionary jurisdiction for inadequate inquiry into TDS on commission and brokerage expenditure arises where the Assessing Officer merely calls for TDS details without examining a material mismatch between financial-statement expenditure and TDS reporting. A substantial increase in expenditure and a claim that amounts retained by franchisees constituted discounts rather than commission require specific examination of contractual arrangements, accounting treatment and TDS liability. Failure to conduct that inquiry may render an assessment erroneous and prejudicial to Revenue interests, rather than reflecting a prohibited change of opinion. The revisionary order was sustained, leaving the expenditure's nature and tax consequences for fresh assessment after giving the assessee an opportunity to respond.

Ad hoc disallowance of livestock purchases was unjustified where the assessing officer failed to identify missing documents or defects in the banking records, supplier confirmations and purchase details, and made no meaningful inquiry beyond issuing supplier notices. Computer-generated invoices lacking GST particulars did not establish bogus purchases because live bovine animals were GST-exempt and suppliers were not required to register. Thumb impressions on cash-purchase vouchers, without adverse material, likewise did not disprove genuineness. The disallowance treated as business income was deleted.

Section 69A was considered in relation to income from other sources that had been included in taxable income and on which advance tax, tax deducted at source and self-assessment tax had been paid, but which was omitted from the corresponding return schedule. The material also addresses appeal limitation where High Court directions permitted filing without reference to limitation and required exclusion of the period of pendency.

Section 80-IA(4) deduction for infrastructure development may be available to an EPC enterprise executing Government water, sewage and industrial-effluent projects where it substantively develops eligible infrastructure and satisfies statutory conditions. A contractual description as a works contractor does not, by itself, bar eligibility. Consistency with an earlier decision on substantially similar facts applies where no material factual or legal change, or contrary higher-forum ruling, is shown. On these principles, the deduction was sustained and the Revenue's challenge failed.

Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.

Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.

Documented gift funding and traceable bank transfers can explain a spouse's contribution to an immovable-property purchase. Donor confirmation identifying fixed-deposit liquidation, together with matching same-date debit and credit entries, supported acceptance of the stated source. Regular mutual-fund SIPs for a minor child were likewise treated as explained where bank debits, modest periodic investments, and clearing credits supported the claim of salary savings. Consequently, the additions for unexplained property and mutual-fund investments were deleted; the reopening issue remained academic and computation required verification under law.

Natural justice is not breached where the taxpayer receives repeated opportunities, issue-specific show-cause notices, and consideration of replies and evidence; the challenge to assessment validity therefore failed. Cash deposits require credible proof of source and a transaction-specific cash trail; unsupported deposits were treated as unexplained money. Consideration for land-facilitation work was characterised as business income because the land was not established as a capital asset and no refundable obligation was proved. GST-reported sales omitted from the revised income-tax return were treated as undisclosed business receipts absent cogent rebuttal. The contested additions and assessment were sustained.

Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature.

Redevelopment hardship and displacement compensation received for vacating residential premises under a redevelopment agreement is treated as a capital receipt where it is not consideration for independent services or otherwise revenue in nature. Its taxability does not depend on alternative-accommodation rent or an erroneous offer to tax. Gross salary reported in Form 26AS does not by itself determine taxable salary; exempt components, including eligible gratuity, require component-wise examination against Form 16 and settlement records. Documentary proof of a qualifying donation and bank payment supports the deduction. Savings-bank interest included in gross total income qualifies for the corresponding deduction within the prescribed limit.

Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.

Skill-based online-game prizes fall within taxable income; the term "winnings" is not limited to chance-based games. However, online-gaming taxability applies only to real net winnings, not gross wallet credits. Repeated circulation of funds, player buy-ins and recycled gaming amounts cannot independently constitute taxable winnings, notwithstanding the bar on deducting expenditure. Where gaming activity results in a net loss and no real net winnings arise, an addition computed on gross online-gaming credits is unsustainable and must be deleted.

Customs-duty liability arising from confiscation and redemption is distinct from the original Bill of Entry assessment. Statutory interest, where payable, cannot accrue before that consequential liability is determined in confiscation proceedings, although departmental delay does not by itself eliminate interest. Interest charged from the original assessment until adjudication was therefore unsustainable and requires recomputation from determination of liability, subject to reassessment and payments or appropriations. Limited writ review may remain available despite an appellate remedy where undisputed facts raise only the legal question of the period for consequential-interest computation and do not challenge classification, confiscation, redemption fine, or penalties.

MEIS benefits under a beneficial export-incentive scheme cannot be refused solely because 'Y' was selected only for the first item in each electronic shipping bill, where genuine notified exports were made and the exporter otherwise declared an intention to claim rewards. The omission was treated as an inadvertent procedural lapse rather than a bar to entitlement. Absence of physical examination did not defeat the claim, since the initial 'Y' selection did not affect Customs' ability to examine the goods. Processing of the MEIS claim was therefore permitted.

Premature IGST-demand proceedings for alleged non-fulfilment of an EPCG export obligation should be left for Revenue consideration in accordance with law. The High Court found no basis to interfere with the CESTAT order holding that initiation was premature. CESTAT observations on revenue neutrality, based on the assessee's data regarding IGST payment and input tax credit, remained subject to Revenue verification and did not bar fresh examination. Revenue may verify the data afresh and decide the matter in accordance with law.

Section 112(a) penalty for an importer's alleged misclassification of removable or exchangeable disc drives was treated as lacking a legal basis where the goods were unavailable at adjudication and no actual confiscation or redemption fine was imposed. The related duty demand and penalties imposed on the importer under the same adjudication order had also been set aside. On these grounds, the Director's penalty for the alleged misclassification was unsustainable and was set aside.

Customs exemption for paver finishers requires the imported machine itself to meet the prescribed paving-width condition when presented for import. Strict construction places the burden on the importer to prove compliance; bolt-on extensions not disclosed in the invoice cannot expand eligibility. The imported machine's undisclosed paving capability constituted misdeclaration, supporting extended-period duty recovery against the importing company. Personal penalty requires a specific allegation and finding of the director's act or omission contributing to the misdeclaration. In the absence of such individualised findings, the director's penalty was deleted, while exemption denial and the extended-period demand remained upheld.

For non-notified goods such as black pepper and socks, the Customs Act places the burden on Revenue to prove their smuggled character before confiscation can be sustained. Failure to discharge that burden means the goods are not liable to confiscation, and penalties imposed solely as a consequence of confiscation cannot stand. The confiscation order and consequential penalties were set aside, with consequential relief.

Financial-institution nominee directors are protected from liability arising merely from their directorship, including good-faith acts or omissions in discharging directorial duties. A nominee and independent non-executive director who had no material relationship or transaction with the company or its management, and no involvement in daily operations, deposit solicitation, or repayment, was not liable for the company's non-compliance with a deposit-repayment order. Criminal proceedings alleging that non-compliance were quashed against that director.