Renewal of registration under section 12AB cannot be rejected solely because the earlier registration certificate was not produced where there is no adverse finding on charitable objects or the genuineness of activities. A subsequently produced certificate must be verified from departmental records. A subsisting registration cannot be treated as invalid through a collateral observation during renewal proceedings; cancellation requires use of the prescribed statutory mechanism, recorded satisfaction, reasonable opportunity of hearing, and a specific written order. The renewal application requires reconsideration after verification of the earlier registration certificate and eligibility under applicable law.

Renewal of charitable registration cannot be rejected for an alleged documentary omission unless the authority verifies the material filed, identifies the specific deficiency, and gives a meaningful opportunity to cure it. Where the earlier registration certificate was assertedly furnished electronically, rejection without confirming its availability or adequacy was unsustainable. The Commissioner, when considering renewal under section 12AB, cannot incidentally declare an existing Form No. 10AC registration invalid; cancellation or withdrawal must follow the prescribed statutory jurisdiction and procedure. The renewal application requires fresh consideration after document verification, an opportunity to provide further material where necessary, and a reasoned decision.

Binding jurisdictional precedent required electricity transferred from captive power units to be benchmarked at the State Electricity Board supply rate, as exchange-traded short-term power was not materially comparable; the electricity adjustment was deleted. Steam had commercial value and could not be valued at nil; prior accepted cost-based valuation required deletion of the adjustment. LIBOR applied to foreign-currency loans, and the interest adjustment fell within the statutory tolerance range, so it was deleted. Hybrid-seed pricing required fresh transactional TNMM analysis after considering extraordinary conditions. Building-sale treatment and tax, MAT-credit, TCS-credit and demand computations required verification and rectification.

Dismissal of an appeal as time-barred without granting a repeatedly requested virtual personal hearing breaches principles of natural justice. Where delay is attributed to pursuing an alternative writ remedy, it may constitute sufficient cause depending on the facts and requires consideration after hearing the appellant. Paragraph 13 of the e-Appeals Scheme, 2023 requires a requested personal hearing to be provided through video conferencing or video telephony. The appellate dismissal was set aside, and the matter was remanded for fresh adjudication after a personal hearing.

A consequential assessment framed solely under a revisional order lacks an independent legal basis once that foundational order is quashed. Where the coordinate Bench's order quashing the revision remains neither stayed nor reversed, it continues to bind despite a pending High Court appeal. The consequential assessment therefore cannot survive, and the appellate order annulling it was upheld in favour of the assessee.

Cash deposits during demonetisation were explained as marriage gifts retained for household and medical contingencies, including the needs of a specially-abled step-son and an ailing mother-in-law. The absence of complete documentation and the time gap between the marriage and deposit did not, by themselves, establish unexplained money. In the absence of material linking the cash to an undisclosed source, unaccounted business activity or other incriminating circumstances, the explanation was treated as reasonable and satisfactory. The addition for unexplained money and consequential special-rate taxation were deleted.

Section 50C did not apply where oral land-sale agreements fixed consideration and purchasers paid advances through banking channels before guideline values were revised. The beneficial first proviso to section 50C applied retrospectively, and a written agreement was not required. Because the guideline values on the oral-agreement dates were below the declared sale prices, capital-gains additions based on later registration-date values were deleted. Income from other sources was attributable only to the assessee's actual share; the quantum required verification by the Assessing Officer.

Penalty for misreporting of income under Section 270A requires the tax authority to identify the precise applicable limb of the statutory definition. Where neither assessment nor penalty proceedings specify which of the six misreporting limbs is invoked, the taxpayer lacks notice of the definite charge. The omission renders the penalty action legally defective, and the penalty cannot be sustained.

Expenditure incurred to implement closure of a business undertaking is not deductible under Section 37(1) merely because it shares common management or control with a continuing business. The closure payment transferred the undertaking's assets, liabilities, employees, contracts and obligations for closure, rather than serving the assessee's ongoing business; its disallowance was restored. Foreign exchange fluctuation loss must be determined from actual liabilities on individual import transactions where records are available, not estimated apportionment. As the claimed loss related to spares and consumables and capital-goods fluctuation had been capitalised, the estimated disallowance could not be sustained.

Interest on partners' running capital accounts is allowable where the partnership deed authorises it and daily running credit balances, rather than opening or closing debit balances, establish the accrued liability. Under mercantile accounting, year-end journal credits do not by themselves make the expenditure fictitious when supporting records substantiate the computation and recipients recognise the income. Interest credited to a lender is not disallowable under section 40(a)(ia) where tax deduction and deposit are established and the recipient has included the amount in taxable income. Banking-channel transfer is not an additional condition once interest is credited and subjected to tax deduction.

Separate satisfaction notes are required for each assessment year before initiating proceedings under Section 153C. Recording one common satisfaction note for multiple years fails to establish jurisdiction independently for each year and vitiates the initiation of proceedings. The assessments initiated on the basis of a common note covering six assessment years were therefore invalid and annulled in favour of the assessees.

Interest earned by a co-operative society on funds statutorily required to be deposited with co-operative banks qualifies for deduction under section 80P(2)(d) of the Income-tax Act, 1961. Section 58 of the Karnataka Co-operative Societies Act, 1959 required placement of funds with a co-operative bank or scheduled bank, and the resulting interest was treated as business income. Decisions classifying interest on retained sale proceeds as income from other sources are distinguishable because these deposits arise from a statutory obligation. Jurisdictional High Court decisions, including one concerning the same assessee, support the deduction for interest from deposits with co-operative banks.

Goodwill recognised as an accounting entry following demerger, representing excess liabilities over assets of a demerged undertaking, did not involve acquisition, transfer, sale, lease or use between associated enterprises. It therefore was not an international transaction for transfer-pricing reporting purposes. Amortisation was added back in computing taxable income, relevant facts were disclosed for Form 3CEB preparation, and non-reporting was supported by bona fide and reasonable cause. A vague, mechanically issued penalty notice further undermined penalty proceedings. Penalty for failure to report the goodwill transaction was not leviable.

Outright payments for software acquired from a Malaysian associated enterprise, where accepted in transfer-pricing proceedings as an arm's-length acquisition of software product and related rights, are characterised as business income rather than royalty. Without a permanent establishment in India, the Malaysian enterprise's business income is not taxable in India under the treaty, so no withholding obligation arises. Separate consideration for intellectual-property rights is treated as royalty; withholding requirements are satisfied where tax has been deducted at the applicable treaty rate. Accordingly, the remittances do not result in default status or consequential interest liability for failure to withhold tax.

Foreign exhibition-sale proceeds already assessed as business income in final settlement proceedings under the Income-tax Act cannot be reassessed as undisclosed foreign income under the Black Money Act, 2015. Income-tax Act assessments computed under the business-income provisions fall within the exclusion in section 4(2) of the 2015 Act, while section 4(3) prevents income included under that Act from also forming part of total income under the Income-tax Act. As the settlement order remained conclusive and unmodified, reassessment of the same foreign-sale income would constitute impermissible double taxation. Additions under the Black Money Act were therefore unsustainable, and deletions for the relevant assessment years were upheld.

Issuance of notice under Section 143(2) after a return is filed in response to a Section 148 notice is a mandatory jurisdictional requirement for reassessment. Treating the return as invalid due to absent e-verification does not remove that obligation. The assessee's participation in reassessment proceedings cannot cure the failure to issue the statutory notice through Section 292BB. Consequently, reassessment proceedings conducted without a Section 143(2) notice are vitiated and the reassessment order is nullified.

Appellate authorities may condone delay and entertain substantiated exemption claims not made in an original or revised return, because the restriction on fresh claims applies to the Assessing Officer and does not limit appellate powers. BSNL Voluntary Retirement Scheme, 2019 compensation was treated as retrenchment compensation eligible for exemption under Section 10(10B), despite an earlier claim under an incorrect provision. Retired BSNL employees were also treated as Central Government employees for leave-encashment exemption, with the beneficial enhanced limit applied in appellate proceedings under Section 10(10AA).

Section 153C proceedings against an "other person" depend on the deemed date when seized books, documents or assets are received by that person's jurisdictional Assessing Officer, rather than solely on the original search date. This deemed date determines both the relevant assessment years and the statutory exclusion applicable after 1 April 2021. Where the seized material was received and satisfaction was recorded after that cut-off, recourse to section 153C was unavailable. The resulting notices and consequential assessments lacked jurisdiction and could not be sustained.

Section 56(2)(x) permits adoption of the stamp duty value on the date an agreement fixes consideration, where full or part consideration is paid through prescribed banking modes on or before that date. An allotment letter may constitute such an agreement for sale. Where property was allotted at the agreed consideration and instalments were paid through banking channels before registration, the subsequent registration date does not determine the applicable stamp duty value. The analysis states that the stamp duty value on the allotment date, rather than the registration date, must be adopted.

Trading loss from identified penny-stock scrips cannot be treated as unexplained income under Section 68 where the assessee substantiates transactions through recognised stock exchange records, securities transaction tax payments, contract notes, banking records, broker ledgers and demat statements. In the absence of evidence linking the assessee to price rigging, accommodation entries or entry and exit operators, assumptions about the scrips and human probabilities do not establish that the loss was bogus. The deletion of the Section 68 addition was therefore supported.