Section 54 exemption remains available where capital gains are invested in a new residential property within the prescribed period, even if they were not deposited in the Capital Gains Account Scheme by the due date under section 139(1). The analysis treats the time available under section 139 as including the extended filing period under section 139(4). Actual utilisation of the capital gains for the qualifying residential investment therefore constitutes sufficient compliance, and failure to make the specified deposit by the original return-filing due date does not defeat the exemption.

Revision under Section 263 was valid because the assessment allowed depreciation on BOT toll-road development cost as an intangible asset without examining the binding CBDT Circular requiring amortisation over the concession period where road ownership does not vest in the assessee. Failure to apply the circular constituted inadequate inquiry. Prevailing High Court decisions also treated BOT-road development expenditure as not creating a depreciable intangible asset, so acceptance of a contrary Tribunal view was not a sustainable possible view. The assessment was therefore erroneous and prejudicial to Revenue interests, supporting revision.

Section 41(1) applies only when a trading liability is remitted or ceases and the assessee obtains a corresponding benefit. Long-outstanding sundry creditors, supported by confirmations and ledger accounts, do not become taxable merely because they remain unpaid or may be time-barred; nor can liabilities relating to earlier years be assessed as unexplained credits in the relevant year. The creditor-liability addition was therefore deleted. Differences between contract receipts in Form 26AS and recorded receipts require verification where the assessee claims that payer deductions represent VAT, insurance, TDS or other allowable business expenditure. The unreconciled amount was restored for verification and allowance if substantiated.

Refusal of charitable registration for non-furnishing of activity details, despite a requested adjournment, denied an effective opportunity to submit relevant material. The registration application must therefore be reconsidered on merits after providing a proper opportunity, consistent with natural justice. An approval application rejected under an earlier filing timeline had to be assessed under the subsequently inserted provision permitting a trust that has commenced activities to apply at any time, because that provision was operative when the rejection was made. The donor-approval application must be treated under the amended framework and decided according to law.

For trusts already undertaking charitable activities when provisional approval under section 80G(5) is obtained, the six-month application period tied to commencement of activities should not be applied retrospectively. A harmonious and purposive construction treats the requirement as applicable to institutions commencing activities after receiving provisional approval; existing institutions must apply at least six months before that approval expires. The Finance Act, 2024 amendment allowing applications at any time after commencement supports this interpretation. Accordingly, a Form 10AB application filed within that period is maintainable and requires verification of substantive eligibility rather than rejection solely as time-barred.

Delayed filing of Form No. 10B does not, by itself, defeat a charitable trust's exemption where its accounts were audited, the audit report was uploaded before the income-tax return, and the substantive conditions for charitable application of income were met. Timely filing of the audit report is treated as a procedural and curable requirement rather than a substantive condition precedent in those circumstances. The claimed exemption, actual application of income and permissible statutory accumulation must therefore be granted, with charitable income recomputed accordingly. Delay in filing the appeal was also condoned where it resulted from the tax representative's inadvertent failure to communicate notices rather than deliberate inaction by the trust.

Disallowance relating to exempt income may be restricted to the taxpayer's voluntary disallowance where the assessing authority has not recorded statutory dissatisfaction with that computation before applying Rule 8D; such disallowance is not included in book-profit computation. Brand equity fees paid for contractual use of business names, marks and marketing indicia may qualify as revenue expenditure. Discounts on gift cards and vouchers crystallise on sale and may be deductible in that year despite later redemption, with expired unused balances offered to tax. Taxable refund interest may be assessed on a net basis after setting off interest charged for advance-tax default under applicable precedent.

Reassessment notices issued beyond three years require material showing escaped income, represented in prescribed forms, meeting the statutory threshold. Housing-finance loan disbursement records and builder receipts established that substantial property consideration came from a housing loan, but the order initiating reassessment disregarded that evidence. Subsequent scrutiny examined only loans from relatives and did not dispute the housing loan, leaving the balance amount requiring examination below the statutory threshold. The reassessment notice was therefore time-barred, and the consequential reassessment order was quashed.

Mandatory faceless reassessment procedures require reassessment notices to be issued through automated allocation and a faceless mechanism. The central-charge exclusion described applies to assessment orders, not to issuance of reassessment notices, so it does not permit a Jurisdictional Assessing Officer to issue such notices outside the prescribed process. A challenge to the officer's inherent authority under the faceless regime is distinct from an objection to territorial or case-assignment jurisdiction. Accordingly, the statutory time restriction for jurisdictional objections does not bar a challenge alleging that the notice was issued without inherent jurisdiction. Non-compliance with the mandatory faceless notice mechanism renders the resulting reassessment proceedings unsustainable.

Delayed receivables from associated enterprises constitute an international transaction, but any notional-interest adjustment must reflect corresponding payables to the same associated enterprise arising in the ordinary course of business. The assessing authority or transfer pricing officer must verify the nexus between those receivables and payables and compute an adjustment only on the net receivable amount. Where an adjustment remains after netting, the applicable benchmark rate is LIBOR plus 200 basis points rather than LIBOR plus 450 basis points.

An unregistered allotment letter may constitute an agreement fixing consideration for the first proviso to section 56(2)(x) where consideration is paid through prescribed banking modes on or before the agreement. The proviso protects genuine property transactions in which consideration was fixed before registration but stamp duty value later increased; it does not require registration of the agreement. Requirements for registration to transfer title are distinct from determining when contractual consideration was agreed. However, entitlement depends on verifying the flat's identification, allotment, payment linkage, agreed consideration and applicable stamp duty valuation.

Sale proceeds from inherited residential property are assessable as capital gains where title records, society membership, transfer documents, inheritance and possession establish ownership. A disputed ownership claim does not permit taxation of gross immovable-property consideration under Income from other sources without establishing its taxability under that residuary head. The deceased husband's status as merely a nominee could not rest on an unverified signature comparison and a non-conclusive declaration against the wider documentary record. The property qualified as a capital asset, allowing indexed cost and deduction for investment in a new residential property, subject to arithmetical verification.

For capital-gains computation, the substance of an integrated land-sale transaction prevails over its description as a vacant-land conveyance. Where demolition of an existing building is integral to delivering vacant possession, its indexed cost or fair market value may be treated as cost of improvement, subject to verification, and the resulting loss may be set off according to law. Stamp duty under a family settlement deed is deductible only to the extent attributable to the transferred property and the taxpayer's share, subject to verification. Section 54 relief is unavailable because vacant land, not a residential house, was transferred. Post-amendment Section 54F relief is limited to one qualifying residential unit, subject to verification of ownership conditions.

A return filed within the period allowed under a notice for reassessment is treated as a return required under the general return-filing provision. The timely-filing condition for Chapter VI-A deductions is therefore satisfied when the return is furnished within that reassessment-notice period. Deduction for interest from deposits directly connected with the reassessment is not an unrelated claim. Where the Assessing Officer examined and accepted the deduction claim on a sustainable view, the assessment is not erroneous and prejudicial to Revenue interests. Revision cannot be supported by grounds beyond the show-cause notice and the basis of the revision order.

Section 250(4) empowers the first appellate authority to call for or direct further inquiry independently of Rule 46A. Material requisitioned under that power is not voluntary additional evidence, while Rule 46A(4) preserves the authority's ability to obtain documents or witness evidence. Educational institutions existing solely for education without profit motive qualify for exemption under Section 10(23C)(iiiab) when Government grants exceed half of total receipts; registration under Section 12A or 12AB is not required for that exemption. Cash-deposit additions require reconciliation with cash books, bank entries and supporting records; where verification is incomplete, the source of deposits requires fresh factual examination.

A subsisting registration under Section 12A(1)(ac)(i) remains legally valid unless cancelled through the exclusive procedure in Section 12AB(4). That procedure requires statutory grounds, inquiry, a reasonable opportunity of hearing, and a written cancellation order. The Commissioner cannot treat an existing registration as defective or invalid while deciding renewal without invoking and complying with that cancellation mechanism. Consequently, rejection of a renewal application solely by disregarding an uncancelled registration is invalid and must be set aside.

Interest and dividend from compulsory, fixed-deposit and savings-bank deposits of a co-operative credit society may qualify as business-income deduction where the deposits are deployed in its ordinary regulated lending activity, rather than representing its own surplus or operational funds. Reassessment initiated beyond the ordinary limitation period is invalid where the alleged escaped income that survives assessment falls below the prescribed threshold and is not represented by the required asset, expenditure or book entry. A penalty based solely on a quantum assessment restored for fresh assessment must be reconsidered after the fresh quantum determination.

Registration under section 12AB requires genuine activities that are charitable in substance, not merely connected with an educational institution. Providing transport to a defined class of students for consideration does not itself advance or impart education unless it has a direct, proximate and dominant nexus with educational advancement. Recurring surplus does not by itself defeat charitable status, but that principle applies only where the underlying activity is charitable. The registration authority may examine the true substance and predominant purpose of activities rather than rely solely on trust-deed recitals. The transport activity was treated as a commercial service, so registration was rejected.

Maturity proceeds from a foreign life-insurance policy were treated as neither undisclosed foreign income nor an undisclosed foreign asset where the premium sources were satisfactorily explained. Premiums paid from salary earned during non-resident status, which was not chargeable to tax in India, and later from disclosed taxable Indian salary fell outside the category of undisclosed foreign assets under applicable CBDT clarifications. Section 10(10D) exempts sums received under a life-insurance policy without requiring that the insurer be an Indian company; no such restriction can be introduced by interpretation. The proceeds were therefore exempt under Section 10(10D).

Interest earned by a cooperative credit society on fixed deposits with a cooperative bank qualifies for deduction under Section 80P(2)(d), as the exclusion for specified cooperative banks does not deny the investing society's deduction. Under Section 57(iii), audit fees, employee welfare expenditure and common administrative expenses with a direct nexus to income earning are deductible, but gifts to retiring members and Covid-19 donations are not. Depreciation against income from other sources is unavailable unless the income falls within specified Section 56(2) categories. The society's final income must be taxed at the applicable cooperative-society slab rates rather than a flat rate.