Registration under section 12AB and approval under section 80G require verification of the genuineness of an applicant's activities. A prior remand for fresh examination does not require grant solely on self-attested material already filed. Failure to provide requested records concerning educational activities, approvals, accounts, staff payments, fees and donations may justify inability to verify genuineness. Where non-compliance resulted from the applicant's mistaken belief that no further documents were required after remand, the applications may be restored for fresh consideration with a further opportunity to submit relevant self-attested or self-certified documents.

Interest earned on compulsory statutory deposits with co-operative banks is attributable to a co-operative society's business of providing credit facilities to its members. Where deposits are mandated by the Karnataka Souharda Sahakari Act, 1997, the interest constitutes business income eligible for deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961. Treating such interest as income from other sources is inconsistent with the principles applicable to compulsory statutory investments.

Where rectification establishes that no tax demand survives, the Tribunal may use its inherent appellate powers to direct refund of tax recovered while the rectification application was pending. The rectification granted the claimed tax deducted at source credit and calculated a refund after adjusting the recovered amount; a further refund remained due even without that adjustment, showing that the original demand had been extinguished and the recovery amounted to duplicate collection. Such relief may be necessary in exceptional circumstances to prevent arbitrary recovery from frustrating the statutory appellate process.

CSR payments to institutions meeting the prescribed conditions remain eligible for deduction under section 80G because, although Explanation 2 to section 37(1) excludes CSR expenditure as business expenditure, section 80G contains no corresponding exclusion for qualifying CSR donations. Separately, for a continuing block of building assets, written down value must be reduced by actual sale consideration as the moneys payable under section 43(6)(c). The stamp-duty valuation fiction under section 50C is confined to capital-gains computation and cannot be extended to depreciation or written-down-value computation without express legislative provision.

Allowability of a bank-guarantee amount reported as a contingent liability in Form 3CD requires verification of the underlying accounting entries, whether reporting was gross or net, the amount's nature, and its connection with other years before an adjustment can be sustained. Cash-paid electricity expenses require verification of payment circumstances, installations, banking access and the claimed Rule 6DD exception before disallowance under Section 40A(3). Both issues were remanded for fresh factual determination after reasonable opportunity to present relevant material.

Approval under section 153D must be separately accorded for each assessment year, even where proceedings concern the same assessee. A single combined communication approving assessments for multiple years does not meet this requirement. Consequently, combined approval for ten assessment years was treated as invalid, and the resulting assessments were quashed in favour of the assessee.

Rental income from leased properties is assessable as income from house property where the facts do not show that commercial exploitation through letting is itself the assessee's business activity. The ITAT Delhi noted that the assessee had returned the receipts under that head, claimed the statutory standard deduction, and carried on trading-related activities rather than a property-letting business; it directed recomputation accordingly. The objection that limited scrutiny had been impermissibly converted into complete scrutiny failed because the record established selection for complete scrutiny.

Reassessment notices issued after expiry of the surviving limitation under the substituted reassessment regime, read with TOLA, are described as void and incapable of supporting a consequential reassessment. The text states that TOLA did not extend the applicable limitation in the stated circumstances, rendering the notice time-barred. It also explains that sale receipts treated as unexplained cash credits cannot remain included in turnover used to compute returned income, as this may create a double addition. The accounts require fresh verification of transport records and payment details, followed by recasting of turnover and income without duplication.

Income cannot be estimated solely from a decline in profit ratio where regularly maintained audited books, including sales, purchases and stock records, are accepted and not rejected under section 145(3). Reduced profitability supported by seasonal business conditions, adverse crop conditions, sales returns and exceptional prior-year margins does not justify a low-profit addition without contrary material. Dealer scheme expenses are allowable where scheme details, dealer-wise and transaction-wise workings, credit notes, invoices, ledgers, confirmations, and evidence of settlement or reversal establish that the liability crystallised and directly related to relevant-year sales. Unsupported doubts cannot displace substantiated accounting treatment.

Corporate social responsibility expenditure disallowed as business expenditure under section 37(1) may nevertheless qualify for deduction under section 80G when the statutory conditions are met. Section 80G operates separately at the total-income computation stage under Chapter VIA, and a statutory obligation to incur CSR expenditure does not negate the voluntary character of a donation where the donor receives no reciprocal benefit. Denying section 80G relief solely because the payment formed part of CSR expenditure would create a double disallowance. The deduction is available subject to computation in accordance with law.

Liability recorded under a trade creditor's name remained payable to a retired partner, as consistently reflected in earlier balance sheets and supported by partnership retirement documentation and the retired partner's confirmation. No material established remission or cessation of that liability. Accordingly, the addition for cessation or remission of liability under Section 41(1) was unsustainable and deleted.

Section 23 revision under the Black Money Act requires an assessment order to be both erroneous and prejudicial to Revenue interests; failure to conduct required inquiries or verification may satisfy that standard. Revision is not justified where the assessment record demonstrates repeated examination of a discretionary foreign trust, trustee minutes, alleged distributions, foreign assets and bank accounts, with explanations and compliance-scheme declarations already considered. Reassessment of material previously examined, without identifying falsity or a specific inquiry defect, amounts only to a possible difference of view. Assets declared under the compliance scheme and taxed with penalty are not again chargeable on beneficiary distribution, while unparticularised trustee minutes do not establish actual undisclosed receipts.

Specific TDS provisions for co-operative societies carrying on banking business govern interest on time deposits paid to co-operative housing societies, overriding the general exemption for payments between co-operative societies. Interest exceeding the prescribed threshold was therefore subject to TDS, and the bank could be treated as an assessee in default. Relief under the proviso to section 201(1) may be available where the recipient has filed its return, included the interest in taxable income, and met the prescribed conditions; verification by the Assessing Officer is required before granting that relief.

Difference between an assessee's total personal capital and capital recorded in a partnership firm cannot be treated as unexplained credit merely through an incorrect comparison. Opening capital was reflected in returns for earlier assessment years, while the increase during the relevant year was supported by disclosed partnership profit share, remuneration and other recorded receipts. As no material rebutted the continuity and source of the capital, the addition under Section 68 was unsustainable and stood deleted.

Revision under section 263 requires a demonstrated error that is prejudicial to Revenue and cannot rest on reappreciation of material already examined during limited scrutiny. The ITAT found that reconciliations and supporting records addressed TDS credit, professional receipts and payout advances, including external-counsel amounts not constituting the assessee's income; revision was therefore invalid. The difference between Form 3CD and book expenditure was reconciled as gross TDS-reporting payments versus net expenditure, with no resulting prejudice; revision also failed on that ground. Expanding beyond the show cause notice through vague directions for broad verification constituted an impermissible roving reassessment. The revisionary order was set aside and the original assessment restored.

A section 54 deduction may be claimed in a return filed in response to a section 148 notice where it directly relates to the long-term capital gain assessed in reassessment. Reassessment may consider a deduction connected with escaped income and does not treat such a claim as an attempt to reopen unrelated concluded matters. Timely filing of an original return under section 139(1) is not a condition precedent to section 54 relief. The Assessing Officer must verify the substantive conditions for investment in a residential property and allow the deduction where those conditions are satisfied.

COVID-19 exclusion of limitation for judicial or quasi-judicial proceedings does not extend statutory due dates for furnishing TDS statements. Consequently, late-filing fee remains applicable under section 234E unless a specific statutory or administrative relaxation covers the relevant statement. Circular No. 12/2021 extended the due date for the final quarter of financial year 2020-21 to 15 July 2021, requiring recalculation of default for assessment year 2021-22, but providing no corresponding relief for assessment year 2022-23. Interest under sections 201(1A) and 220(2) remains payable where tax payment and conditions protecting against default are not established; waiver of section 220(2) interest lies before the prescribed authority.

Section 50C valuation requires an effective opportunity for the taxpayer to contest a Departmental Valuation Officer's report where the taxpayer has objected to stamp-duty valuation. Completion of assessment before receipt of the valuation report, without allowing objections on matters such as land access, comparable sale instances and adopted rates, requires fresh determination. The valuation-based addition was restored for reconsideration after examining the taxpayer's objections and any registered valuer's report.

Reassessment under sections 147 and 143(3) cannot be sustained where the section 148 notice is issued by an officer without pecuniary jurisdiction under CBDT Instruction No. 1/2011. For a corporate assessee in Delhi whose returned income fell below the threshold allocated to an Assistant Commissioner or Deputy Commissioner, jurisdiction lay with the Income-tax Officer. As the instruction binds departmental authorities, issuance of notice by the ACIT constituted a defect in the inherent authority to assume jurisdiction. The reassessment proceedings were therefore void and quashed.

Project receipts recognised under the consistently applied Percentage of Completion Method cannot be taxed again in the year of receipt to the extent already adjusted against revenue and offered to tax in subsequent accepted assessments. Verification is required to identify any unadjusted balance, which may be treated as income for the relevant year. Tax deduction at source on acquisition of development rights did not apply where the payment preceded the commencement of the relevant withholding provision, and the related disallowance provision had not yet been extended to such payments. Consequently, denial of the acquisition cost for non-deduction of tax was unsustainable.