Money-laundering allegations involving a respondent's knowledge of bank deposits and participation in concealing proceeds of crime require trial where the evidentiary record cannot conclusively resolve those disputed facts at the quashing stage. Pre-trial assessment of recovery evidence and the respondent's knowledge improperly determines evidentiary merits that must be tested through adjudication. Quashing of the proceedings was therefore unwarranted, and the allegations must proceed to trial.

Modification of preference-share redemption terms complied with the class-rights variation requirements because identical terms were offered to all preference shareholders and written consent exceeded the prescribed three-fourths threshold; no separate sub-class meeting was required. Interim asset-preservation relief must be ancillary to and support the final relief claimed in the suit. As the suit challenged the annual general meeting resolution while the application sought restraints on dealing with assets, the requested protection was not sustainable. Earlier interlocutory orders did not operate as res judicata because they expressly left all issues open for decision. The interim order's confirmation was therefore invalid.

Customs test reports must be handled through coordination between investigating and customs authorities while testing remains pending. Non-disclosure of results during that period required explanation, particularly because the record contained an apparent inconsistency regarding whether the reports were available. Additional respondents were permitted to be impleaded, notice was issued, and further hearing was scheduled to clarify the status and availability of the test reports.

Technical write-offs of bad debts relating to non-rural advances are deductible without adjustment against the provision for bad and doubtful debts, as the two deductions operate independently. Provision for bad and doubtful debts must be calculated using aggregate average outstanding rural advances: monthly closing advances for each rural branch are aggregated, averaged and then combined, rather than limited to fresh advances made during the year. Minimum alternate tax does not apply to a nationalised corresponding new bank that is not formed or registered under the Companies Act, notwithstanding its deemed Indian-company status for specified income-tax purposes.

Charitable scholarships for students studying abroad and medical assistance for treatment abroad remain eligible applications of income in India where the trust disburses the financial aid in India. The relevant consideration is the situs of disbursal for the charitable purpose, not the location where a beneficiary subsequently receives education or medical treatment. Objects requiring scholarships and assistance to be awarded or rendered in India therefore do not contemplate application of trust funds outside India and do not breach the requirement under Section 11 of the Income-tax Act, 1961. Refusal of approval on a contrary reading was unsustainable, requiring fresh adjudication.

Long-term capital gains from listed-share sales cannot be treated as unexplained cash credit solely on a general penny-stock investigation report where the taxpayer substantiates the transactions. Banking-channel purchases, dematerialised share holdings, recognised stock-exchange sales through a registered broker, securities transaction tax payment, and bank receipt of sale proceeds support genuineness when the supporting records are not defective. Absent material linking the taxpayer to price manipulation, accommodation entries, or collusion with alleged operators, suspicion arising from price movement, company fundamentals, or a general modus operandi cannot displace the evidentiary record. The sale consideration is not assessable as unexplained cash credit, and the claimed long-term capital gains remain allowable.

Joint ownership and evidence of payment support deduction of housing-loan interest even where the bank certificate names only the other co-owner. Interest disallowance was therefore deleted because joint acquisition and the claimant's payment rebutted any presumption that no interest was paid. Salary-linked provident fund contributions deducted by the employer and substantiated LIC investments qualify for deduction under Section 80C; absence of additional documentation did not justify denial in the circumstances. The disallowance of the balance Section 80C claim was also deleted.

Revisionary jurisdiction cannot be used to order unspecified further enquiry where the Assessing Officer examined the long-term capital-gain computation, verified the difference from Form 26QB, and adopted a plausible view. A brief assessment order does not by itself establish lack of enquiry. The Principal Commissioner must identify a specific error and independently examine the assessment record; revision based on an audit-driven proposal without such satisfaction is jurisdictionally deficient. As no error prejudicial to Revenue was established, the revisionary action and consequential revision order were quashed.

A registered sale agreement, payment of consideration and delivery of possession collectively constituted a transfer of immovable property for section 56(2)(vii)(b). The difference between the ready-reckoner value and agreed consideration was therefore taxable despite non-execution of a conveyance deed. Pending property litigation and the absence of a later sale or conveyance deed did not alter the legal effect of the registered agreement and possession. The addition under section 56(2)(vii)(b) was sustained.

Circular No. 9/2024 applies to pending departmental appeals, implementing the enhanced monetary threshold and the exceptions retained under Circular No. 5/2024. The audit-objection exception previously available under Circular No. 3/2018 was superseded and not retained in the later circulars. Accordingly, where the tax effect is below the prescribed limit and no current exception applies, a Revenue appeal is not maintainable and must be dismissed.

Investment of entire sale proceeds in construction of a residential house supports deduction where credible material, including a municipal certificate, establishes the construction. Non-production of bills and vouchers alone does not justify denial absent cogent material disproving the investment. Where the full sale consideration is so invested, a separate deemed-income addition based on stamp-duty value cannot be sustained on the same facts. The stated principle links substantiated residential-house construction with both allowance of the deduction and deletion of the related deemed-consideration addition.

Section 270A distinguishes under-reporting from misreporting of income and applies separate statutory penalty rates. Misreporting requires identification of an applicable circumstance specified under section 270A(9); absent such identification, a higher misreporting penalty cannot be sustained. The statutory scheme does not contemplate a 100% penalty for under-reporting. On the stated merits, the penalty was not exigible and was quashed.

Denial of an exemption or deduction claim during return processing, when the new registration number was unavailable and a rectification application remained pending, required fresh consideration. The matter was to be reconsidered by the Assessing Officer after providing a reasonable opportunity of hearing, and the prior order was set aside for a de novo decision in accordance with law.

Assessment annulment based on alleged non-issuance of a show-cause notice under CBDT Instruction No. 20/2015 was considered unsustainable where the assessment record showed repeated scrutiny notices and questionnaires, and the assessee had submitted extensive financial and supporting documentation. The record therefore contradicted the finding that no opportunity had been provided. As the merits of the additions and disallowances had not been argued, those matters required determination by the appellate authority and were restored for decision on merits.

Timely digital filing of Form No. 10B by the statutory auditor, before filing the return, constitutes substantial compliance with the audit-report requirement for exemption under sections 11 and 12. Where subsequent verification was delayed by technical difficulties and the return was filed on the verification date, rejection solely because approval was belated would be an impermissibly hyper-technical approach. Delayed verification in these circumstances does not defeat the trust's exemption claim.

Revision under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer obtained and examined labour-payment, tax-deduction and subcontractor details, accepted the employer-employee character of daily-wage labour payments, and applied tax deduction requirements where applicable, a tax-audit-report non-disclosure alone did not show lack of inquiry. Directing re-examination of the same material without identifying a specific error or defect amounts to an impermissible fishing inquiry and delegation of revisional authority. A plausible view taken after inquiry cannot be revised merely because further inquiry or another view is preferred. The revisionary order was quashed.

Dismissing an assessee's appeal before considering detailed submissions filed on the adjourned date denied an effective opportunity of hearing and breached principles of natural justice. The appellate order had been passed before the requested filing date due to a communication gap or technical error, preventing the assessee from placing its case before the appellate authority. The matter was remanded for a fresh decision on merits after granting due and adequate hearing opportunity.

An income-tax appeal was dismissed because the assessee's authorised representative appeared at a virtual hearing without the dress prescribed under the applicable standard operating procedure. Non-compliance with the prescribed virtual-hearing attire requirement resulted in dismissal of the appeal.

Reassessment for assessment year 2015-16 was stated to be barred because the six-year limitation period under the former regime expired on 31 March 2022. The relaxation framework under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not extend time for a notice issued after that expiry. Supreme Court rulings were identified as requiring reassessment notices for that year issued on or after 1 April 2021 to be dropped. Consequently, a notice issued under section 148 on 3 April 2022 was described as time-barred, depriving the reassessment proceedings of jurisdiction and requiring the assessment under section 147 to be quashed.

Interest awarded under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsorily acquired agricultural land is characterised as an accretion to the land's value and forms part of enhanced compensation, rather than income from other sources. This differs from interest under Section 34, which compensates for delayed payment. Amendments governing taxation of interest on compensation address the timing of taxation and do not change the character of Section 28 interest. A contrary High Court view was treated as inapplicable against the Supreme Court position, and a non-speaking dismissal of a special leave petition was not a binding declaration of law.