Business-promotion expenses were treated as business-related but only partly substantiated, resulting in restricted disallowance. Letter-of-credit charges and software-development expenditure were treated as allowable because partial capitalisation lacked a sustainable basis and a one-time payment alone did not establish capital character. Foreign-exchange loss, fixed-deposit interest additions, unsupported expenditure, gratuity provision and tax-payment claims remained disallowed for lack of reconciliations, accounts, supporting particulars or proof of payment. Ad hoc disallowances for engineering stores and printing and stationery were reduced as the original rate was excessive. Taxable income requires recomputation after giving effect to deleted, restricted and sustained disallowances.

A notice under Section 148 for Assessment Year 2015-16 was beyond the limitation period applicable under the pre-amendment regime, which expired on 31 March 2022. The first proviso to Section 149(1), inserted by the Finance Act, 2021, preserves that restriction for past assessment years. The fifth and sixth provisos, which provide exclusion and extension mechanisms within the amended three-year or ten-year framework, cannot extend the limitation preserved by the first proviso. Consequently, the notice dated 7 April 2022 was time-barred, invalid, and incapable of conferring jurisdiction for reassessment.

Revisionary jurisdiction under section 263 cannot be invoked merely because the Assessing Officer could have conducted further or more extensive enquiries. Specific notices, explanations, books, bank records, confirmations, invoices, e-way bills, GST records and affidavits were examined, and additions were made after considering seized material. A finding that an assessment is erroneous and unsustainable requires support from the assessment record or an independent enquiry. The revision proceedings also overlooked a rectification order enhancing the accommodation-entry addition and did not examine the record of prior assessment approval. The section 263 order was therefore quashed.

Corporate social responsibility donations to institutions approved under section 80G remain deductible under that provision where no express exclusion applies, despite their non-deductibility as business expenditure under Explanation 2 to section 37(1). Denial solely because the payments discharge mandatory CSR obligations would create an unintended double disallowance. Interest under section 234C requires verification and recomputation of advance-tax liability. Interest on refunds under section 244A requires verification of relevant dates, including refund issuance, with additional interest to be granted if legally due.

Notice for assessment under the Black Money Act was issued beyond the timeline prescribed by CBDT Guidelines. Information on the undisclosed foreign asset was available to the Department in April 2019 and, at the latest, when reopening reasons were recorded in March 2021. The Guidelines required a section 10(1) notice preferably within 30 days after the relevant previous year, with written reasons and competent-authority approval for delay. No recorded reasons or approval supported the delayed March 2022 notice. As the administrative instructions bound the Revenue, the notice was time-barred and consequential proceedings were null and void.

Scientifically estimated warranty provisions based on historical trends are described as deductible trading expenditure under Section 37(1), where sale creates a present contractual obligation and expected costs are matched with recognised revenue. Withholding tax contractually borne by an assessee on a net-of-tax royalty payment is treated as part of the royalty consideration and allowable business expenditure. For in-house scientific research, Section 35(2AB) is described as requiring DSIR approval of the research facility, not certification of the expenditure amount; qualifying expenditure, excluding land or building costs, should therefore not be restricted to DSIR-quantified amounts. Consequential interest is stated to require recomputation.

For assessments under section 153C, where the Assessing Officer of the searched person and the other person is the same, transfer of the other person's case and seized material to that officer is treated as the relevant handing-over date. Where records were transferred under section 127 before the satisfaction note was recorded, limitation runs from the transfer order, not from the later satisfaction note. On the stated facts, the assessments were treated as time-barred and quashed.

Delayed furnishing of Form 67 is treated as a procedural, technical and venial lapse and does not by itself justify denial of an otherwise admissible foreign tax credit. Where the income-tax return was filed within time and Form 67 was uploaded before the rectification application was considered, the delay may be condoned. The foreign tax credit remains subject to verification and grant in accordance with law.

Writ proceedings concerning reassessment notices were remitted for fresh consideration in light of a subsequent statutory amendment and Supreme Court directions. The writ appeal was allowed, the single judge's order was set aside, and the writ petition was restored for reconsideration. Liberty was reserved to challenge Section 147A of the Income-tax Act.

Reassessment notices issued solely on the basis of the Shah Commission report concerning illegal mining were treated as unsustainable where a coordinate-bench ruling in a similar factual setting, applying relevant High Court precedent, supported the assessees' challenge. The reassessment notices and all consequential proceedings were quashed in favour of the assessees.

Loans or advances received by a public trust from a company in which its managing trustee held substantial shareholding cannot be treated as deemed dividend under Section 2(22)(e) on the stated facts. The provision extends the meaning of dividend but does not treat a non-shareholder recipient as a shareholder, and a public trust is not among the specified concerns in Explanation 3. In the absence of evidence that the trust was a conduit for the trustee's individual benefit, the deeming provision does not apply. Reassessment proceedings based on that premise were therefore invalid.

Deletion of the disallowance of loss on sale of shares did not raise a substantial question of law where similar transactions for the preceding assessment year had been accepted as genuine on documentary evidence. As no contrary material was produced to displace that evidence, the same reasoning applied for the relevant year. The Gujarat HC noted that the Tribunal's earlier decision had already been confirmed and that the issue was decided in favour of the assessee.

Trade-promotion activities of an association representing mandap contractors can advance an object of general public utility where its dominant purpose is to organise events, share knowledge, educate members, encourage the trade and represent collective interests, rather than profit-making. Incidental benefits to members do not negate charitable character. For registration under Section 12AA, the prescribed documents may establish the creation or establishment of a trust or institution; separate registration with the Registrar of Companies, Firms and Societies, or Public Trusts is not an absolute precondition. The rejection of registration on these grounds was unsustainable and required fresh consideration under law.

Charitable status for advancement of objects of general public utility remains available where the activities retain their charitable character, supporting exemption. Trust income is computed on normal commercial principles, allowing depreciation on assets used for its functional purposes as plant and machinery. Excess charitable application in an earlier year may be carried forward and adjusted against subsequent income. The statutory entitlement to accumulate 15% of income is optional, not mandatory; it cannot be used to reduce a deficit arising from expenditure exceeding receipts. Such subsequent adjustment constitutes application of income for charitable purposes.

Additions based on allegedly artificial sales and rejection of books require material showing that invoices were fabricated or book entries were false. A comparison with earlier transactions is insufficient where the disputed sales arose in materially different circumstances, including increased customer demand during demonetization. The Tribunal treated the sales as genuine on its factual appraisal, as both genuine and accommodation-sale explanations were possible on the evidence. The Rajasthan HC found that this factual conclusion was not perverse and that no substantial question of law arose.

Wilful attempt to evade tax under Section 276C(2) requires a deliberate, intentional and conscious act to evade tax, penalty or interest; mere delayed payment without mens rea is insufficient. Disclosure of income, requests for time due to business closure, periodic payments with interest and full discharge of liability before substantive progress of prosecution do not, without a specified evasive act, establish the offence. A criminal complaint must identify facts demonstrating wilful evasion, and an order issuing process must properly scrutinise whether those essential ingredients are prima facie disclosed. Where no such act or circumstances are pleaded, prosecution and process are unsustainable.

An assessment order cannot stand where a show-cause notice issued on a Sunday allows only three days for response and the taxpayer's subsequent reply and request for a video-conference hearing are not considered. Such limited time fails to provide a reasonable opportunity of being heard, and the grievance concerning inadequate response time must be addressed before assessment is completed. The assessment was vitiated for breach of natural justice, requiring a fresh assessment after adequate hearing opportunity, including a personal hearing where permitted by law.

Fixed place permanent establishment issues concerning NIPL, Nokia OY and a liaison office in India were raised, including the existence of a PE and attribution of income. The Special Leave Petition was filed after a delay of 383 days. The text records that the reasons for condonation were found unsatisfactory and legally insufficient, so the condonation application and the Special Leave Petition were dismissed. It also notes an earlier petition involving the same respondents and issues that had been dismissed for gross delay, and states that filing a later petition with greater delay could have been avoided.

Software purchase payments to non-residents were described as not constituting royalty and therefore not requiring withholding under section 195, consistent with the Karnataka High Court decision referred to in the text. The Supreme Court did not examine that substantive characterisation: it found the reasons for a 307-day delay in filing the Special Leave Petition unsatisfactory and legally insufficient, dismissed the condonation application, and consequently dismissed the Special Leave Petition solely on delay.

Section 44B applies to a non-resident operating ships for carriage of passengers and permits presumptive income computation from amounts paid or payable for that carriage. Passenger carriage need not involve travel between two distinct ports: a round-trip voyage returning to its origin remains carriage, particularly where passengers may disembark at intermediate ports. Hospitality and entertainment provided on board are ancillary to cruise operations and do not alter the activity's essential character. A non-resident cruise operator conducting such voyages falls within the presumptive-income regime under Section 44B.