Faceless reassessment jurisdiction under Sections 147 and 144B extended to the National Faceless Assessment Centre before Notification No. 18/2022 where binding CBDT directions under Section 119 required it to complete reassessments, subject to specified exclusions. The later Section 151A notification did not invalidate reassessments completed under the earlier faceless-assessment framework. Additions for cash payments and rent income made in an ex parte assessment required fresh appellate adjudication because the assessee's continuing mental illness prevented effective participation. The first appellate authority must provide three effective opportunities to furnish supporting material before deciding those additions on merits.

Bank deposits arising from xerox and fabric-trading transactions cannot be assessed in full as unexplained cash credits where the related withdrawals, transaction details and stock particulars indicate genuine business activity. Although handmade supporting bills were not accepted as reliable, taxation must be confined to the income element embedded in alleged bogus cash receipts rather than the gross deposits. Applying the presumptive-taxation standard, income is estimated at 8% of the cash receipts deposited in the bank account.

Domestic companies with turnover below the prescribed threshold are taxable at the 25% rate under the applicable Finance Act. Eligibility depends on the statutory conditions, not on an incorrect reference to section 115BA in the return. A mistaken provision cited while claiming the lower rate does not permit taxation at 30% where the Finance Act independently prescribes the 25% rate. The applicable rate must therefore be determined from the company's eligibility under the Finance Act.

Reassessment cannot be used to recharacterise property-sale proceeds already assessed as long-term capital gains as business income solely by revisiting the same assessment record. Where the original scrutiny considered the sale transaction and the property had consistently been shown as a fixed asset, an audit-driven reopening requires fresh tangible material establishing income escapement. A different view of the same facts is an impermissible change of opinion, rendering the reopening and consequential reassessment invalid.

Interest disallowances relating to unsecured loans required fresh adjudication because substantially similar issues for the preceding assessment year had been restored for de novo consideration. The outcome for that preceding year was material to determination for the relevant year. No view was taken on the merits, and the appellate authority was required to reconsider the matter after providing adequate hearing opportunity, together with the connected preceding-year proceedings.

Jurisdictional objections to reassessment, including challenges to notice, statutory procedure and disposal of objections, must be adjudicated before addressing additions on merits. Section 250(6) requires an appellate order to identify points for determination, decide them and provide reasons. The discretionary power to set aside a best-judgment assessment for fresh assessment does not remove this duty. The validity and effect of filings made through a deceased assessee's electronic account require record-based examination without a stated conclusion. A reasoned speaking order must determine the legal and jurisdictional grounds before any remand of merits.

Dividend distribution tax under Section 115-O was contested on whether the India-Netherlands tax treaty rate could apply instead. Pending Supreme Court proceedings against the jurisdictional High Court ruling on the same issue, together with directions to consider staying comparable matters, required judicial discipline and precluded adjudication at that stage. The issue was restored for fresh adjudication after the Supreme Court decision.

Transferable development rights received in exchange for surrendered land constitute capital assets acquired at an ascertainable cost: the cost attributable to the land surrendered. Their subsequent sale is therefore taxable under capital gains provisions, with that attributable land cost deductible in computing the gain; the rule for self-generated assets with no conceivable acquisition cost does not apply. Verification of a refund claim did not restrict scrutiny of the claimed exempt receipt where no limited-scrutiny restriction was stated. Acceptance of exemption in another taxpayer's assessment does not compel identical treatment, as an erroneous or unexamined assessment does not bind tax authorities or create estoppel against correct statutory application.

Ind AS accounting recognition does not independently determine taxable income where the Income-tax Act or ICDS prescribes a different computation. Notional income from unwinding an interest-free security deposit, royalty already taxed as upfront consideration, EPCG duty benefits connected with assets, and borrowing-cost differences under ICDS IX were not taxable or disallowable merely because of Ind AS presentation; the related additions were deleted. Absence of Form 3CL could not defeat deduction for an approved in-house research and development facility where issuance lay with the prescribed authority. TDR cost and set-off, leave-entitlement provision, and gift expenditure required verification of prior records, computation treatment, business purpose and evidence, and were restored for fresh determination.

Reassessment based on an audit objection requires objective material showing that identified disclosed credits are non-genuine; suspicion arising from alleged non-verification of sundry creditors is insufficient. Cash payments for purchases of raw hides and skins are permitted under section 40A(3) read with Rule 6DD(e)(ii). Where books record sellers' or creditors' names and relevant mandi details, and no material casts doubt on those particulars or the sellers' existence, failure to provide PAN or addresses cannot support an adverse inference absent a legal requirement to maintain them. Reopening on these facts lacks jurisdiction and amounts to an impermissible fishing enquiry.

Reassessment based on seized third-party material requires a live and direct nexus with the taxpayer's transaction. An inquiry-register entry recorded before the registered land purchase described land available for sale, covered additional survey numbers and a larger area, named an unconnected person, and did not refer to the taxpayer or co-purchasers. The broker's admissions further undermined any assumption that every entry reflected an actual financial transaction. Mere overlap in some survey numbers could not establish undisclosed on-money payment, rendering the reassessment notice unsustainable.

Depreciation is allowable under Section 32(1)(ii) of the Income-tax Act, 1961, on acquired brand names and marketing and distribution networks where they constitute business or commercial rights of similar nature. Such assets fall within the statutory category of depreciable intangible assets, alongside specified rights such as trade marks, licences and franchises. Where included in the opening written-down value of the relevant block of assets, the acquired brand name and marketing and distribution network qualify for depreciation.

TDS credit must be granted where the deductee establishes that tax was actually deducted, even if the deductor failed to deposit it or file TDS statements. Sections 199 and 205 require harmonious construction: the deductee is protected from double taxation and cannot be made liable for obligations beyond their control, while recovery action remains available against the defaulting deductor. Form 16 or Form 16A is not the exclusive proof of deduction; salary records, bank statements, payment documents, ledgers, payer confirmations and other contemporaneous evidence may establish a prima facie claim. The Department must verify such evidence and keep mismatch demands non-prejudicial during verification.

Appellate jurisdiction over a Tribunal order lies with the High Court having territorial jurisdiction over the Assessing Officer who made the assessment order. The assessee's location and any subsequent centralisation of the assessment do not change that jurisdiction. Where the assessment order was made by an Assessing Officer outside the High Court's territorial limits, the appeal is not maintainable before that High Court and must be filed before the appropriate jurisdictional High Court.

Consideration from sale of software licences to non-residents, where no right or interest in the copyright is transferred, is not royalty taxable in India. Such payments do not require tax deduction at source. The position was consistent with the principle applied in earlier proceedings involving the same taxpayer.

Reassessment initiated after four years from the end of the relevant assessment year requires fresh tangible material and a demonstrated failure by the assessee to disclose fully and truly all material facts. Re-examining balance-sheet, profit-and-loss and land-sale particulars already furnished and considered in the original scrutiny assessment is merely a change of opinion. Where the recorded reasons rely only on such existing material and identify no disclosure failure, reopening under Section 147 lacks jurisdiction and the reassessment is invalid.

Selection of the Most Appropriate Method for transfer-pricing benchmarking, including preference for the Transactional Net Margin Method over the Comparable Uncontrolled Price Method, is generally a factual determination. Intervention under section 260A is not warranted merely because of differing views on method selection or related economic and pricing adjustments, unless findings are perverse or conflict with Rules 10B and 10C. Where documentary material supports the factual findings, consequential transfer-pricing adjustments remain incidental to the method-selection issue and do not independently raise a substantial question of law.

Sufficient cause under the Limitation Act may justify condonation of administrative delay where the explanation demonstrates bona fide scrutiny, internal opinions and approvals, document collection, settlement of the appeal memorandum, and filing approval. A justice-oriented, pragmatic approach focuses on the adequacy of the explanation rather than the duration of delay. In the absence of mala fides or factual inaccuracy, handwritten dates in a condonation application do not alone establish a mechanical or stereotyped explanation. The delay in filing the Revenue's appeal was therefore treated as sufficiently and bona fide explained and condoned.

Section 153C requires the satisfaction note and consequential notice to be issued immediately after the searched person's assessment proceedings. A ten-month interval between completion of those proceedings and issuance of the satisfaction notes and notices was not a reasonable time. On identical facts involving the same assessee for other assessment years, the binding determination governed the position. The delayed Section 153C notices were therefore time-barred and invalid.

Transfer and centralisation under Section 127 require a subsisting administrative or investigative purpose. Where the transfer of an assessee's case to Nashik was justified by coordinated investigation with a searched person, completion of that person's assessment before issuance of the transfer orders removed the stated basis for centralisation. With no remaining reason to shift the case from Mumbai, the transfer orders were quashed and the assessee's assessment was required to proceed under the appropriate Mumbai charge.