Recurring advertising, publicity and sales-promotion expenditure, including visual printing, promotional activities, website applications, hoardings, radio advertising, event management and sponsorships, constitutes revenue expenditure where it supports business in a competitive market without creating a capital asset or enduring benefit. Consistency in income-tax assessments requires the Revenue not to depart from treatment accepted in earlier and later years, including scrutiny assessments, unless fundamental facts materially change. On those principles, capitalisation of the expenditure was rejected and the corresponding addition deleted; other grounds remained open.

Agricultural land located within municipal limits is a capital asset, while aerial-distance and population criteria apply only to land outside those limits. Municipal jurisdiction on the transfer date must be established through underlying official material rather than an unproduced report, requiring fresh verification. An agricultural-land reinvestment exemption may be claimed for the first time before the Tribunal where relevant facts are already on record, but depends on proof of prior agricultural use and the qualifying purpose of replacement land. Stamp-duty valuation adjustment on purchase also requires reconsideration after determining whether the taxpayer disputes the value. All issues require fresh adjudication after evidence and hearing.

Profit estimation on unrecorded ready-mix concrete sales must have a reasonable nexus to the material and cannot replace an accepted turnover working without supporting evidence. Where audited results for the same activity showed a gross loss and the books were neither rejected nor found defective, departing from the year-specific approach adopted in prior assessments was unsupported; the estimated gross-profit addition was deleted. Cash-credit provisions require a credit in the taxpayer's own books. Off-book pen-drive entries attributed to unrecorded sales could not support a cash-credit addition, particularly where taxing full receipts beyond their profit element would result in double assessment. The cash-credit addition was deleted.

Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.

Foreign tax credit on foreign dividend income cannot be denied solely because the prescribed form was furnished after the original-return due date but before the revised return and the end of the assessment year. Where the governing statute imposes no filing deadline and the procedural rule neither links delay to denial nor lists delayed filing as a disqualifying circumstance, the filing requirement operates as directory. Rectification is available where processing annexures recognise foreign tax credit as available but the computation simultaneously records it as nil, since that internal inconsistency is a mistake apparent from the record. The credit is to be allowed, while the processing adjustment remains open to challenge.

Uncorroborated statements recorded during a survey cannot alone support an addition for estimated income as unexplained money where no unrecorded money or specified valuable article is found, audited books are not shown incorrect, and no incriminating material exists. The addition was deleted. Delayed electronic furnishing of a tax audit report may constitute reasonable cause when accounts were audited and the report signed within time, but uploading was omitted due to the auditor's illness, without intent to evade tax. The related penalty was deleted.

Penalty for deemed income based solely on stamp-duty valuation is not justified where the taxpayer disclosed the registered deed, bank statements and payment details, and there is no finding that actual consideration exceeded the stated amount or that disclosures were false. Although statutory substitution of stamp-duty value can support an assessment addition, it does not alone establish concealment or inaccurate particulars, and the conditions for penalty are not met where the explanation is not found false. Acceptance of the addition does not admit that the stated consideration was untrue. Conversely, a notice expressly alleging concealment provides a specific charge when the penalty rests on that same allegation.

Penalty for under-reported income is not automatically attracted merely because a first return is filed in response to a reassessment notice and accepted without variation. The statutory trigger must be read with the exclusion for a bona fide explanation and full disclosure of material facts. The use of "may" preserves discretion in imposing penalty. Relevant indicators of bona fides include audit-related delay, an undisposed request to file the return, prompt filing after notice, verified declared figures, and payment of tax and interest. Treating bona fides as irrelevant without reasoned consideration is inconsistent with this framework; on the stated facts, the penalty was deleted.

Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.

Conversion of a capital asset into stock-in-trade under a joint development arrangement requires proof that the asset entered the assessee's business stock; executing such an arrangement alone, particularly without a real-estate business, does not establish conversion. On that basis, the long-term capital-gains addition was deleted. A transfer of flats to a spouse without actual consideration, made to safeguard property interests, is not a sale merely because a sale deed records consideration. The deed recital cannot establish income received, and the business-income addition was deleted.

Reassessment under sections 148A(b) and 148A(d) requires the reasons recorded for reopening to correspond with the information and grounds put to the assessee for explanation. Where a notice treated land as undisclosed and an unexplained investment, but the subsequent satisfaction accepted its disclosure and instead questioned the source of acquisition funds, the basis of reopening changed completely. Fresh or supplementary reasons cannot sustain reassessment without prior notice under section 148A(b). The Tribunal therefore quashed the reassessment, leaving the merits of the addition unadjudicated.

Non-conformity of a scrutiny notice under section 143(2) with the CBDT-prescribed format is treated as a procedural defect curable under section 292B, rather than one invalidating the notice or consequential assessment. In appellate proceedings, material admitted as additional evidence must be made available to the Assessing Officer for examination under Rule 46A. Deletions based on unexamined material, or made without recorded reasons, require reconsideration through a fresh, reasoned assessment after hearing the assessee. The notice challenge was rejected, while disputed additions were remitted for de novo assessment.

Tax deduction at source on interest arises on credit or payment, whichever occurs first; a brought-forward interest liability does not itself constitute a current-year credit. The real income doctrine requires objectively established contemporaneous circumstances showing that income did not accrue, rather than merely an absence of accounting entries. Unexplained-expenditure provisions apply to expenditure incurred in the relevant financial year and do not extend to an earlier capital advance merely carried forward, particularly where recorded in regular books. A capital work-in-progress write-off already added back in computing business income should not be added again, as this would result in double taxation. Interest capitalised to work-in-progress is not subject to disallowance where tax was deducted and deposited within the prescribed return-filing timeline.

The test of human probabilities permits tax authorities to look beyond documentary evidence and banking-channel payments when assessing the real nature of a political contribution. Donation receipts and bank payments did not prove genuineness where investigation material, statements, bank-trail analysis, and the recipient party's modus operandi showed systematic fund layering for accommodation entries. The apparent transaction was not a genuine political contribution; the claimed deduction was denied, the consequential addition sustained, and the assessee's appeal dismissed.

Section 50B prescribes a self-contained method for computing capital gains on a slump sale, including fair market value and net worth under Rule 11UAE. Where no defect in the valuation methodology or non-compliance with Rule 11UAE is identified, the Assessing Officer cannot substitute a different valuation; deletion of the resulting capital-gains addition was confirmed. A capital-gains addition made without a proper show-cause notice also breached CBDT Instruction No. 20/2015 and was independently unsustainable. The Revenue's appeal was dismissed.

For capital gains exemption under section 54F, a shop-cum-office verified as commercial cannot be treated as an additional residential house when applying the ownership condition. The denial based on its classification as a residential house was therefore removed, subject to satisfaction of the remaining statutory conditions. For section 54B, agricultural land does not lose its agricultural character merely because it is situated in an urban area. Reinvestment relief was available to the extent supported by purchase deeds and other documentary evidence establishing eligible investment.

MEIS benefit processing requires a shipping bill's Reward declaration, inadvertently entered as 'N', to be corrected to 'Y' in the EDI system after Customs has made the corresponding manual correction. The amended shipping bills must then be electronically transmitted to DGFT under the prescribed public-notice procedure so that the MEIS claim can be implemented. Administrative technology must facilitate, rather than obstruct, a rectifiable procedural correction; the specified Customs and DGFT actions are to be completed within four weeks of communication.

Revenue must establish tariff reclassification through evidence of each imported article's objective characteristics, applicable tariff entries, Section Notes and Explanatory Notes; representative sampling, undisclosed website material and unreasoned end-use assertions were insufficient. The proposed reclassification and consequential denial of concessional duty failed. Extended limitation required pleaded and proven collusion, wilful misstatement or suppression; a corrigendum could not add new articles or bills of entry, and charges first introduced through it ran from its date. The extended-period demand was unavailable. Duty determination had to reconcile annexures and appropriate verified payments, so the unreconciled demand failed. Inc.....

Section 28 permits recovery of unpaid or short-paid anti-dumping duty through a demand notice without first challenging the importer's self-assessment. This recovery mechanism is distinct from refund proceedings, where an unmodified self-assessment may restrict relief. Anti-dumping duty imposed under the Customs Tariff Act is treated as customs duty for calculating IGST on imported goods; IGST therefore applies to the aggregate value including such duty. The maximum penalty for non-payment is governed by the statutory ceiling applicable on the date of import, and a subsequently enhanced ceiling cannot apply retrospectively.

Minimum Import Price restrictions regulate imports entering the domestic market for home consumption and do not apply to goods warehoused under Customs control exclusively for re-export. A declared value below the Minimum Import Price, or higher National Import Database data alone, does not establish undervaluation without corroborative evidence of under-invoicing, additional consideration, or deliberate misdeclaration. Where the Minimum Import Price premise does not apply, rejection and redetermination of declared value cannot survive. The declared assessable value was restored, consequential confiscation, redemption fine and penalty were set aside, and re-export was permitted subject to procedural requirements.