Interest deduction under Section 43B requires loan-wise evidence linking accrued term-loan interest with payments made before the return-filing due date. Consolidated financial statements, ledger accounts and bank statements may not establish that nexus; primary payment evidence, including a bank certificate, may require fresh verification. Expenditure disallowance under Section 14A read with Rule 8D does not arise where no exempt income was earned during the relevant previous year. Accordingly, the interest claim remains subject to factual verification, while the exempt-income-related disallowance is unsustainable.

Rectification or recall under section 254(2) is unavailable where alleged non-consideration concerns a coordinate-bench order that was not available at the hearing and was not specifically relied upon in the grounds or Tribunal record. Failure to consider a jurisdictional High Court judgment may support rectification in appropriate circumstances, but that principle does not permit review of an earlier order through section 254(2). The alleged omission therefore did not constitute an error apparent from the record, and the assessee could not obtain rectification or recall.

Limitation for a rectification application under section 154(7) commences when the intimation is communicated to the assessee, rather than on the date appearing on the intimation. Where the assessee did not receive the intimation and became aware of the demand only through recovery proceedings, limitation cannot be calculated solely from the intimation date. The rectification application therefore could not be rejected as time-barred on that basis; the delay was condoned and the matter was restored for adjudication on merits.

Reversal of opening accrued or unbilled revenue is allowable where revenue was consistently recognised on the mercantile basis according to work performed, offered to tax on accrual, and retained as an asset until billing. Amounts reversed on subsequent billing, including earlier-year billing adjustments, do not create fresh taxable income where they were already recognised and taxed. Professional fees paid to non-resident member firms do not attract withholding-based disallowance where the payments are not consideration for protected rights, know-how, or information constituting royalty under the applicable tax treaties, and the recipients have no permanent establishment in India. Consequently, disallowance for non-deduction of tax is not sustainable.

Recurring trademark fees paid under a non-exclusive, time-bound licence are allowable as revenue expenditure where the licensor retains exclusive ownership and the user acquires only a limited contractual right to use the mark. Annual fees calculated as a percentage of gross profit, coupled with an obligation to stop using the trademark on termination, do not create proprietary rights, exclusive commercial rights, or an enduring capital asset. The payments are operational expenses deductible under Section 37(1) of the Income-tax Act, 1961.

Penalty for under-reporting of income under section 270A cannot be sustained where the notice and penalty order fail to identify the specific clause of section 270A(2) allegedly breached. General references to under-reporting create ambiguity and invalidate the penalty proceedings. Penalty is also unwarranted where relevant receipts were disclosed and non-taxability was claimed on a bona fide legal position. A rejected claim or addition arising from debatable questions concerning royalty, business income, permanent establishment or profit attribution does not justify penalty absent concealment or non-disclosure of material facts.

Section 153C requires the Assessing Officers of both the searched person and the other person to record jurisdictional satisfaction. Assessment limitation runs from handover of seized material, and a later satisfaction record does not invalidate proceedings absent breach of a prescribed timeline or demonstrated prejudice. Cross-examination and supply of a third party's statement are required only when the statement underpins an adverse addition; seized spreadsheet evidence and corroborating transaction data may instead support the addition. A satisfaction note need not finally quantify undisclosed income. Where electronic records support cash consideration for jointly acquired property, the addition requires recomputation according to the assessee's verified ownership share.

Failure to satisfy the conditions for the concessional corporate tax regime under Section 115BAA requires computation at the applicable normal rate. Where a company's turnover in the relevant preceding financial year did not exceed the prescribed threshold, its income is taxable at the normal corporate rate of 25%, rather than 30%. Denial of the concessional rate does not itself trigger the higher normal rate; the applicable ordinary rate remains determined by the turnover-based condition.

Comparable Uncontrolled Price (CUP) Method may benchmark exports to associated enterprises where independent purchases provide reliable comparables and material differences can be adjusted; unsubstantiated objections based on geography, volume or timing do not displace CUP. TNMM may be unreliable for a first-year producer without meaningful capacity-utilisation adjustments. Foreign-currency borrowings require currency-specific arm's length benchmarking that accounts for tenure, security, credit and market risks; a uniform LIBOR spread without comparables is insufficient. Delayed foreign-currency receivables constitute a separate international transaction, with interest benchmarked at LIBOR plus 200 basis points after a 60-day credit period rather than domestic deposit rates. Transfer-pricing relief applies to export sales and external commercial borrowings.

Reassessment notices issued more than three years after the relevant assessment year require material revealing escaped income of at least Rs. 50 lakh and prior sanction from the higher specified authority. These conditions are mandatory for assuming reassessment jurisdiction. Where the alleged escaped income was below that threshold and approval came from the Principal Commissioner rather than the authority prescribed for delayed notices, jurisdiction was not validly assumed. The reassessment notice was invalid, and the consequential assessment was quashed.

Professional banking education provided to an identifiable section of the public constitutes educational charitable activity for Section 2(15); the general-public-utility proviso does not apply, and refusal of approval under Section 10(23C)(vi) does not determine entitlement to Section 11 exemption. Interest on tax-free bonds is consequently governed by the charitable-institution computation regime under Section 11 rather than Section 10(15). Section 11(6) cannot support a depreciation disallowance where no depreciation was claimed. Accumulation under Section 11(2) is permissible where Form No. 10 identifies definite purposes, including premises, e-learning facilities, and testing, learning and data centres, rather than merely repeating general institutional objects.

Unexplained-income addition based on alleged share-sale proceeds requires assessee-specific evidence linking identified transactions to unaccounted income, sham trades, or accommodation entries. Gross sale consideration cannot be treated as taxable profit without reconciling transaction-wise records and examining the actual income component. Books of account, contract notes, bank statements and broker records supported the reported transactions, while general penny-stock investigation material did not establish a nexus with them. No exempt long-term capital-gains claim had been made. The unsupported addition was deleted, with consequential interest to be recomputed on finally determined income.

Section 14A(2) requires the Assessing Officer to examine the accounts and record cogent, objective dissatisfaction with the assessee's expenditure claim before invoking Rule 8D. Rule 8D is not an automatic computation merely because exempt income exists. A reasoned suo motu disallowance based on proportionate employee and communication costs cannot be increased through general references to common accounts, intermingled funds, transactions or interest expenditure without identifying defects or expenditure with a proximate nexus to exempt income. Unrebutted explanations on interest and interest-free own funds must be addressed. The additional disallowance was deleted, while the voluntary disallowance remained intact.

Unexplained cash credits - unsecured loans - Alleged cash-cheque accommodation entries - uncorroborated electronic material - Disallowance of expenditure relating to exempt income - recording of dissatisfaction Unexplained cash credits - unsecured loans - Identity, creditworthiness and genuineness of loan creditors - additions for unsecured loans where documentary evidence established the identity and creditworthiness of the creditors and the genuineness of the loan transactions - HELD THAT: ... ... ...

Denial of renewal of registration u/s 12AB - trust had not undertaken charitable activities during the relevant years HELD THAT: - Registration concerns the charitable nature of the trust's objects and the genuineness of its proposed activities, and is not an assessment of activities actually undertaken. Where the charitable character of the objects was undisputed, non-commencement of activities could not by itself establish that the activities were not genuine or justify refusal of regis... ... ...

Rectification of mistake apparent from record - Indexed cost of acquisition after compulsory surrender of land on conversion Validity of rectification of long-term capital gains by proportionately reducing indexed cost of acquisition where part of the originally acquired agricultural land was compulsorily retained by the development authority upon conversion into non-agricultural land - HELD THAT: - Rectification jurisdiction is confined to a mistake apparent from the record. The controversy ... ... ...

Characterization of receipt - Capital or revenue character of exclusivity fee for aborted share-transfer joint venture - Disallowance of expenditure relating to exempt income in absence of exempt income Capital or revenue character of exclusivity fee for aborted share-transfer joint venture - Taxability of monetary business benefits - Non-compete receipts - Taxability of the exclusivity fee received upon failure of the proposed joint venture involving transfer of shares in the assessee's ... ... ...

Taxation of registered societies assessed as association of persons - Maximum marginal rate vis-a -vis normal rates under section 167B Applicability of the maximum marginal rate to a society registered under the Societies Registration Act which filed its return in the status of an AOP/BOI - HELD THAT: - The assessee was a registered society which returned income in the status of an AOP/BOI. As the returned income was below the taxable limit, it was eligible for taxation at normal rates under ... ... ...

Bogus purchases of sesame seeds - profit Estimation - HELD THAT: - Where the books of account had not been rejected, the sales stood accepted and the quantitative details furnished by the assessee were not doubted, the entire value of purchases could not be added merely because their genuineness was not substantiated to the satisfaction of the Assessing Officer. In such circumstances, only the profit element embedded in the disputed purchases was liable to be brought to tax. [Paras 13] The ad... ... ...

Penalty u/sec.271B for delayed filing of tax audit report - reasonable cause and bona fide cause for the delay - HELD THAT: - The assessee established a reasonable and bona fide cause for the delay, as the accounts could not be made ready for audit owing to the accountant's illness. The audit report had also been furnished before the return was selected for scrutiny. Consequently, the protection available on proof of reasonable cause applied and penalty was not justified. [Paras 4] The pe... ... ...