Interest on delayed refunds arising from appellate-effect orders for Assessment Years 2014-15 to 2016-17 was directed to be computed under Section 244A(1A) from 1 December 2025 until payment, with additional Section 244A interest for September 2026 if payment was not made within the stipulated period. The Assessing Officer was required to secure consequential payment through the CPC. For Assessment Year 2014-15, the Assessing Officer was also required to verify the difference between tax deducted at source credit in the appellate-effect order and Form 26AS; if a short grant was established, interest under Section 244A(1) would run from 1 April 2014 until payment. No further direction applied to Assessment Year 2009-10.

Preliminary reassessment proceedings under Sections 148A(1) and 148A(3), followed by a notice under Section 148, are investigative steps that do not determine tax liability. Challenges concerning search-based information, applicability of Section 152(3), and sanction under Section 151 should ordinarily be examined during reassessment and through statutory appellate remedies. Writ intervention at this threshold is exceptional, limited to total absence of jurisdiction or a patent breach of a mandatory pre-condition; disputes requiring appraisal of material are not ordinarily examinable under Article 226. The challenge to reassessment initiation was therefore treated as premature, with recourse left to reassessment and appellate processes.

Deduction of cost of funds from deposit income of a primary agricultural credit co-operative society requires fresh consideration in light of Totagars Co-operative Sale Society. The claim for proportionate administrative and other expenditure remains open for adjudication. The impugned intimation, assessment orders and consequential penalty orders for the relevant assessment years were quashed, and the matter was remanded to the competent authorities. The society may submit objections and reply to the notice issued under section 142(1).

Agricultural-land status depends on the cumulative indicators applied in Sarifabibi, including land classification in registered deeds and revenue records, purchaser status and intended use, and the taxpayer's treatment of sale gains. Land described as industrial-purpose, recorded as fallow, sold for non-agricultural use and offered to tax as capital gain was treated as a capital asset rather than agricultural land. Relief for reinvestment in agricultural land requires fulfilment of the statutory conditions, including agricultural use of the transferred land during the prescribed period; industrial-purpose replacement land did not qualify. An unchallenged revisionary order cannot be contested through an appeal from the consequential assessment.

For property devolving on a beneficiary upon dissolution of a private family trust, the previous owner's holding period must be included where the previous owner's cost is adopted under section 49(1). Explanation 1(b) to section 2(42A) requires that deemed holding period to determine whether the asset is long-term; the properties therefore qualify as long-term capital assets. The same holding period applies to indexed cost of acquisition, which must be computed from the year in which the previous owner first held the property. Gains on the sale of such devolved immovable properties are accordingly taxable as long-term capital gains, and the related addition was deleted.

Interest on loans advanced from borrowed funds may remain taxable as income from other sources where the statutory basis invoked for business income applies only to termination or modification of an agency or management contract, and no such contract is established. Revenue cannot replace that basis with a general business-income provision by taking a different stand. Interest expenditure on borrowings used to advance loans generating taxable interest is deductible under section 57(iii) where a reasonable and proximate nexus with earning that income is established. Actual income generation in the same year is not required, and an alleged breach of Companies Rules does not by itself defeat the deduction.

Professional income cannot be assessed by treating an entire doctor's gross receipts as net income solely because no return was filed. For a reasonable assessment, the taxpayer's offer of 50% of receipts as income, tax payment on that basis, and Revenue acceptance of the same approach in subsequent years for the identical profession were relevant, although they did not establish formal eligibility for presumptive taxation under section 44ADA for the relevant year. The Tribunal did not decide whether section 44ADA could be claimed without filing a return. Professional income was restricted to 50% of gross receipts; unpressed grounds were dismissed.

Delayed conveyance of land and building to a housing society, where the promoter had a pre-existing statutory and contractual duty to convey, does not constitute a fresh receipt of immovable property for inadequate consideration merely because registration occurred later. The conveyance perfected legal title and transferred remaining reversionary and leasehold interests in property already possessed and beneficially enjoyed by the society and its members. Intervening disputes explaining delayed registration did not alter the bona fide antecedent arrangement. Consequently, the difference between stamp duty value and settlement consideration was not taxable under section 56(2)(x), and the related addition was deleted.

Outright acquisition of trademark ownership for lump-sum consideration constitutes acquisition of a capital asset rather than payment for the use of intellectual property or continuing royalty. A foreign remittance for such transfer does not by itself create a tax deduction obligation under section 195; withholding applies only where the remitted sum is chargeable to tax in India. Where the assignment agreement, transferred rights, valuation, commercial terms, ownership evidence and recipient's tax residency certificate establish an ownership transfer, the payer cannot be treated as in default for non-deduction of tax. Demands for tax and consequential interest under sections 201(1) and 201(1A) were deleted.

Section 10(4)(ii) exempts interest on NRE deposits where an individual is either a person resident outside India under FEMA or is permitted by the RBI to maintain the NRE account. A change in residential status is therefore not conclusive of exemption eligibility. Continued authority under the applicable RBI/FEMA framework to maintain NRE deposits requires factual verification. Eligibility must be examined on this limited basis, with an opportunity of hearing, without reopening unrelated issues.

Additions for alleged unaccounted consideration in real-estate transactions require cogent, reliable and transaction-specific evidence of actual cash receipt or payment. Differing internal price references, ERP capabilities, employee statements, WhatsApp communications and an unsupported discount-based estimation cannot establish suppressed sale consideration without purchaser-wise proof, cash records, receipts, money trail or parallel books. Estimation may quantify undisclosed income only after its existence is established. Third-party loose sheets primarily attract statutory presumptions against their possessor; corroboration of recorded cheque payments does not prove an alleged cash component. Denial of cross-examination of the sheet's a.....

Section 115BAA concessional taxation remains available in subsequent assessment years once a domestic company validly exercises the option through Form 10-IC. The option applies thereafter and cannot be withdrawn, so a fresh Form 10-IC is not required for each succeeding year. Denial of the concessional rate solely because no new form was filed for the relevant subsequent year is unsustainable.

Section 11(6) bars depreciation as application of income for charitable purposes only where the acquisition cost of the relevant asset has already been claimed as application of income in the same or an earlier year. Where a charitable institution has not claimed capital expenditure on acquiring fixed assets as revenue application and claims only depreciation, the restriction does not create a double deduction. Depreciation on those fixed assets may therefore be treated as allowable application of income for the relevant assessment year.

Segmental aggregation under TNMM prevents a separate nil arm's length price adjustment for intra-group back-office, sales and marketing support services that are integral operating costs of subscription and services segments under an assured-margin model; a separate adjustment would duplicate the segment-level benchmarking. Working capital adjustment must be allowed where differing working-capital levels materially affect comparable margins, despite unavailable daily public balances, subject to verification. Comparable selection requires functional similarity: product developers, education providers, companies with proprietary products or intangibles, diversified operations, entrepreneurial risks, or absent segmental data should be excluded.....

Admission of crucial additional evidence supporting capital-gains exemptions was valid because the Commissioner (Appeals) obtained a remand report and found the supplementary agreement necessary for substantial justice. The agreement amalgamated two adjoining flats into one composite residential unit with a single surviving flat number. The taxpayer's investment and stipulated share in that composite unit supported exemptions under sections 54 and 54F, as the Assessing Officer had not verified facts sufficient to displace that position. The disallowance was deleted and the revenue's appeal was dismissed.

Interest expenditure under section 57 remains deductible where borrowings retain a real nexus with assets generating income taxable under Income from Other Sources. Conversion of investments into sale proceeds and then fixed or term deposits does not, by itself, break that nexus. Deduction is not limited to interest income realised in the same year; arithmetical equivalence between expenditure and annual income is not required. An oral interest arrangement may establish an existing liability when supported by conduct and historical treatment. The creditor's accounting method and timing of taxability of corresponding interest are independently determined and cannot restrict the borrower's otherwise allowable deduction, subject to year-wise quantification, verification, and separate statutory disallowances.

Intra-group management-fee transfer pricing adjustments cannot be sustained where the issue has consistently been resolved in the taxpayer's favour on materially similar facts in earlier years. Tax refunds from customs and VAT/GST are balance-sheet items rather than income; any return-processing adjustment treating them as income requires factual verification and consequential relief under law. Claimed short credit for tax deducted at source must be verified after giving the taxpayer an opportunity to substantiate the claim. Interest charged under the applicable provisions requires recomputation and a clear section-wise bifurcation to enable verification of its correctness. The management-fee adjustment was deleted, while the remaining matters required verification or recomputation.

Sections 92A(1) and 92A(2) require a harmonious reading: the statutory circumstances in section 92A(2), including business dependence under section 92A(2)(g), do not independently establish an associated-enterprise relationship without participation in management, control or capital under section 92A(1). Commercial dependence or distribution exclusivity alone is insufficient absent evidence of ownership, voting rights, managerial participation or financial control. For internal CUP analysis, contractual differences do not disqualify an uncontrolled transaction unless they materially affect the royalty rate and cannot be eliminated through reasonably accurate, objectively verifiable adjustments. Royalty benchmarking was remanded to examine those differences and adjustments; if CUP is unreliable, the most appropriate method must be independently selected.

Sale proceeds of Renewable Energy Certificates received by renewable-energy power generators are treated as capital receipts because the certificates incentivise environmental benefits of renewable generation rather than arise from producing or selling goods or rendering services. They therefore do not constitute business income or profits derived from an eligible power-generation undertaking for deduction purposes. As capital receipts, the proceeds are also excluded from book profit computed for minimum alternate tax purposes under section 115JB. The Revenue's challenge to deletion of the related disallowance and to exclusion from book profit was rejected.

Prospective operation of a customs exemption amendment prevents its use against imports where the Bill of Lading predates the amendment's effective date and no retrospective effect is expressly provided. A request for provisional release of used digital multifunction print, copying and scanning machines must therefore be considered under Section 110A without relying on the later amendment. Release may be granted subject to lawful conditions and remains subject to adjudication. The applicable duty rate is to be determined under Section 15 of the Customs Act, 1962.