Returns filed in response to a reopening notice after the stipulated period may be treated as invalid, limiting challenges based on subsequent procedural requirements. Reassessment is not invalidated for alleged non-issuance or non-service of a notice under Section 143(2) where the taxpayer acknowledged issuance of statutory notices, participated in the proceedings, and Section 292BB applies. A typographical error concerning the assessment year does not alter that position. The requirement to dispose of reopening objections through a separate speaking order does not apply where the return responding to the reopening notice was filed after the permitted time. The merits addition remains unaffected where it is not contested.

Unexplained cash deposits may be assessed as unexplained money under section 69A where the taxpayer fails to produce books of account or other satisfactory evidence proving their lawful source; bank statements and unsubstantiated claims of past savings or interest do not establish source. Exemption under section 10(26) applies only to income arising from a bona fide, valid source in the specified areas or States. Scheduled Tribe status and residence in Arunachal Pradesh do not exempt unexplained funds, because proof of the income source is a condition precedent to the exemption.

Listed-share transfer claims require reliable evidence of ownership movement and consideration, including a demat trail, transfer documents, contract notes, broker confirmation, exchange-trade data and banking records. An offline sale coupled with adjustment against a loan liability does not establish a transfer where those records are absent. The tax treatment of the alleged share sale and loan adjustment requires fresh verification, including whether the transfer was subsequently completed. A notional accounting adjustment that neither effects a real transfer nor reduces liability does not itself create taxable real income. Write-off of an already disallowed debit balance does not constitute unrecorded expenditure, so the related deletion remains undisturbed.

Revision under Section 263 applies where an assessment order is both erroneous and prejudicial to Revenue interests. Treating a cash payment as undisclosed investment without identifying and applying the governing charging provision and special tax rate indicates non-application of mind and can cause loss of tax lawfully payable. Applying an inapplicable penalty provision instead of the provision governing deemed undisclosed income similarly supports revision, as it may undermine consequential penalty proceedings. The revisionary authority may direct fresh inquiry and reassessment under the correct taxation and penalty provisions.

Issuance of Form 3 under the Vivad se Vishwas Scheme renders the related appellate dispute incapable of adjudication after the taxpayer has filed the prescribed settlement forms. Separately, exemption for long-term capital gains on share sales is unavailable where investigation and SEBI adjudication materials establish manipulation and rigging of the scrip's price, and the taxpayer produces no supporting evidence despite opportunities in appellate proceedings. The settlement position and the failure to substantiate the genuineness of the share transactions independently sustain the tax treatment of the disputed gains.

For Assessment Year 2013-14, Section 54EC permitted exemption for investments made within six months of transferring a long-term capital asset. The financial-year ceiling applied to investments made during each financial year; therefore, investments of Rs. 50 lakh in each of two separate financial years within the six-month period qualified for exemption of the full Rs. 1 crore. The later aggregate cap covering the financial year of transfer and the following financial year applied only from Assessment Year 2015-16 and did not affect the earlier year.

Capital-gains computation for an unquoted-share transfer must use the full value of consideration received or accrued from that particular transfer. Actual contractual consideration cannot be replaced by a later transaction's higher consideration or perceived market value unless an express deeming provision applies. Fair-value substitution for unquoted shares applies only where declared consideration is below the value determined under the prescribed valuation rules. Contemporaneous depository and accounting records may establish the completed transfer date and accrual of consideration; subsequent settlement does not alter the transfer's character. Uncorroborated reports of negotiations cannot displace primary contractual and transactional evidence or establish pre-determined consideration.

Unutilised capital gains intended for investment in a new residential house become taxable only when the prescribed investment period expires or non-investment becomes ascertainable. Where the taxpayer remained within that period when filing the return, a later shortfall in the investment could not be assessed in Assessment Year 2014-15, even though it emerged after acquisition of another property and after the revised-return period had expired. As the shortfall was not taxable for that year, it did not constitute concealment of income or furnishing of inaccurate particulars, and penalty under section 271(1)(c) was unsustainable.

Payments by a closely held company to a substantial shareholder do not constitute deemed dividend under Section 2(22)(e) unless they have the character of a loan or advance. Where audited accounts and a running ledger show that the company owed funds to the shareholder throughout the year, the shareholder's account never became debit, and the payment merely reduced the company's existing credit liability, no shareholder indebtedness arises. The absence of a formal loan agreement, interest provision or board approval does not change the transaction's established character. Repayment of funds already due to the shareholder is therefore outside deemed-dividend taxation.

Struck-off companies continue for determining, recovering and discharging outstanding tax liabilities. Sections 248(6), 248(7) and 250 of the Companies Act, 2013 preserve assets for liabilities and sustain the liabilities of directors, officers and members despite dissolution. Reassessment proceedings against such a company, and an appeal concerning those liabilities, therefore remain maintainable rather than becoming infructuous on striking off. Where an unexplained-credit addition was sustained without the company's participation in first appellate proceedings, it may submit supporting material and receive a hearing before fresh determination on merits.

Estimated year-end provisions do not require tax deduction at source under sections 194C, 194H or 194I where no liability has crystallised and no ascertainable amount is credited or payable to an identifiable payee. Accounting estimates recorded before invoices are received, then reversed and subjected to tax deduction when liabilities crystallise, do not create assessee-in-default liability under section 201(1). Where the related expenditure has already been disallowed for non-deduction of tax under section 40(a)(ia), the same default cannot support a further demand under section 201(1). Interest under section 201(1A) is consequential and cannot survive without a sustainable principal default.

Estimated addition for unreconciled cash deposits may be sustained where disclosed bank deposits and accepted business sales lack complete item-wise reconciliation. Where no material shows that deposits arose from a source independent of the disclosed business, only the unreconciled portion may be reasonably estimated rather than the entire deposits treated as unexplained. Such an estimate does not constitute income of the nature covered by section 68 merely because reconciliation is incomplete. Consequently, the estimated addition remains assessable under ordinary provisions and is not subject to the special tax rate under section 115BBE without material or a finding of an independent unexplained source.

Tax deducted at source and remitted to the Government Treasury cannot continue as recoverable principal liability once relevant challans are verified and correlated with the corresponding transactions. Verification must confirm the correct tax amount, deduction date, deposit date and linkage between challans and payments. Payment of principal tax does not remove statutory interest for delayed remittance; interest remains chargeable only for the period from deduction/default until the actual date of deposit. Following verification, the corresponding principal demand must be deleted, while interest is confined to the period of delay.

Ad hoc disallowances of labour and repair expenses cannot rest solely on year-on-year expenditure comparisons without verifying supporting records or identifying bogus or inflated claims. The labour-charge and repair-expense claims require examination of ledgers, invoices and other evidence. Bad-debt deductibility requires factual verification of the receivable's origin, outstanding balance, adjustments, debtor acknowledgments, liquidation status and actual write-off. Unrefunded business-related input tax credit is not automatically non-deductible merely because it was rejected or not refunded under GST; its real nature, irrecoverability and connection with the business must be examined. Ultimate allowability of all claims remains subject to evidence-based determination.

Revisionary jurisdiction under section 263 is not attracted merely because a further or more extensive enquiry into a section 80JJAA deduction may be considered desirable. Where the Assessing Officer has examined the deduction through notices, a proposed disallowance, Form 10DA, employee-wise information, salary details and statutory-contribution records, the assessment reflects a conscious enquiry. Questions over client agreements, operational supervision, salary reimbursements and staffing arrangements concern the adequacy or manner of enquiry, rather than absence of enquiry. Deployment of employees at client premises, client supervision, or salary-cost reimbursement does not by itself displace the employer-employee relationship or additional employee cost for section 80JJAA purposes.

Cash deposits require a satisfactory explanation of their nature and source to avoid treatment as unexplained money. A claim that deposits originated from a partnership firm is not substantiated where the firm's ledger records the underlying sale after the stated cash receipt. Tax on unexplained-money additions remains subject to the rate applicable for the relevant assessment year. An amendment enhancing the tax rate applies prospectively from its stated operative assessment year and does not govern earlier years; the pre-amendment rate therefore applies to the relevant addition.

Section 68 addition is unsustainable where ledger records and supporting material show no fresh loan or unexplained credit during the relevant year, and the entry concerns interest on loans obtained in earlier years. Deemed dividend treatment does not extend to reciprocal, interest-bearing commercial dealings conducted through a current account. Repayments of prior advances and payments made on behalf of related entities do not become loans or advances merely because funds move between them. Strict construction of the deeming provision excludes such mutual commercial transactions, supporting deletion of both additions.

Live broadcasting licence fees were treated as outside royalty taxation under Article 13(3) of the India-UK tax treaty because a one-time live match feed neither confers an enduring benefit nor constitutes a scientific work or copyrighted work. The contractually agreed 95:5 allocation between live and non-live broadcasting rights remained undisturbed, absent material showing it was unjustified; consideration for non-live rights had already been offered to tax. Release fees paid to permit English players' participation in the IPL were also outside Article 18(2), as they were paid for consent and did not arise from the players' personal activities.

WhatsApp chats recovered from a third party's mobile phone cannot, without independent corroboration, sustain an addition for unexplained investment against another person. The presumption under Section 132(4A) applies only to the person from whom material is found and does not bind a third party. Electronic chats require proof of authenticity through the prescribed certificate, and compliance with requirements for extraction of electronic evidence must be demonstrated. In the absence of corroborative evidence establishing the alleged investment and valid authentication of the chats, the addition is liable to be deleted.

Sanction under Section 151 for reassessment must reflect meaningful satisfaction based on relevant facts, records and applicable law. Omission of an earlier assessment under Section 143(3) from the recorded reasons and sanction proforma, a bare endorsement that the matter was fit for notice under Section 148, no reference to supporting material, and an undated approval indicate mechanical sanction without application of mind. Such invalid approval vitiates the notice under Section 148, the assumption of jurisdiction under Section 147, and the consequential reassessment.