Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.

Section 263 revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the Assessing Officer has called for and considered details on unsecured loans and trade payables, revision cannot rest merely on audit objections or an assumption that further inquiry would produce an addition under section 68. Explanation 2 creates a deeming framework for insufficient inquiry but does not remove the twin statutory requirements. In the stated circumstances, the assessment was made after inquiry, no revenue prejudice was identified, and the revisional order was quashed.

Section 194N places the obligation to deduct tax at source on the banking company making a cash payment, not on the customer withdrawing cash. Failure to deduct attracts the statutory consequence under section 271C against the person responsible for deduction. A bank cannot impose a lien on a customer's current account for an alleged TDS liability without statutory authority or a direction from the income-tax authorities. The lien was directed to be released and account operations permitted after the customer furnished income-tax returns for the relevant three consecutive years, without limiting lawful action by tax authorities.

Digital advertising and sales-promotion expenditure on media space, SMS broadcasts, search-engine optimisation, campaign content, marketing videos and social-media strategy is revenue expenditure where it comprises recurring promotional measures, creates no business asset and only improves product promotion through a digital platform. The enduring-benefit test does not make such expenditure capital without an asset or capital-field advantage. Payments for website and mobile-app search services are likewise revenue expenditure where they improve product searches, correct search terms and facilitate sales without creating a capital asset or enduring capital advantage. Disallowances of both categories were deleted; the Revenue's appeals failed and supportive cross-objections became infructuous.

Third-party search assessments under section 153C require the seized material to be handed over to the other person's Assessing Officer before the statutory cut-off. Where handover occurs after 1 April 2021, section 153C is unavailable and proceedings may be pursued only under reassessment provisions; the resulting notice and assessment lack jurisdiction. Penalty for cash acceptance contrary to section 269SS, when unrelated to assessment, is subject to the limitation period beginning with the Assessing Officer's recommendation to initiate penalty proceedings. A penalty order issued after that period is time-barred and liable to be quashed.

Interest expenditure on borrowings used to make interest-bearing unsecured advances is deductible against taxable interest income under section 57 where the nexus is established. The Assessing Officer's findings showed that the advances to private parties were funded through interest-bearing loans from banks and non-banking financial companies. As the borrowing cost was directly connected with earning the interest income assessed under income from other sources, the disallowance was deleted for the relevant assessment years.

Penalty for cash receipts under section 271DA requires proof that the assessee received cash in breach of section 269ST. Where the underlying quantum addition was deleted because the alleged transaction involved other parties and not the assessee, no factual basis remained for a consequential penalty; deletion of the penalty was therefore upheld. The presumptions under sections 132(4A) and 292C apply against the person from whose possession or control seized material is found. A WhatsApp screenshot recovered from another entity's premises, without the assessee's name or admission of cash receipt, could not support a presumption against the assessee. The Revenue's appeal was dismissed.

Section 54F permits exemption based on investment in a residential house through purchase, construction, or a combination of both. The cost of the new asset can include bona fide expenditure incurred after purchase for reconstruction, alteration, renovation and improvements that make the house fit for residence. Habitability of the purchased house and reconstruction expenditure exceeding its purchase cost do not independently restrict the exemption, as no statutory ceiling applies to construction quality or amenities. Expenditure on independent comfort items remains excluded. Where reconstruction expenditure is genuine and not linked to excluded items, the aggregate purchase and reconstruction cost qualifies for the Section 54F exemption.

Interest earned by a co-operative credit society on deposits of surplus profits may qualify as business income attributable to providing credit facilities to members where the deposits are mandated or permitted by the statute governing the society. This differs from interest on members' surplus receipts, which may be taxable as income from other sources. The deduction claim requires verification of the relevant deposit details and reconsideration in line with the applicable High Court principles. Expenditure disallowance for alleged tax-deduction failures and taxability of miscellaneous interest also require fresh examination where the society asserts non-service of a show-cause notice and seeks to furnish supporting particulars, ensuring an adequate opportunity of hearing.

Reassessment against a dissolved partnership firm after its business succession is void where the Department had accepted that the firm ceased to exist and the successor proprietor disclosed and was assessed on the same business transactions and bank accounts. Assessing the erstwhile firm in these circumstances would duplicate taxation of the same business income. Jurisdiction for reassessment also requires recorded reasons identifying the relevant bank account or transaction and foundational material showing income escaped assessment; vague reasons do not meet that standard. A notice issued to a non-existent entity after succession renders the consequential assessment and estimated addition unsustainable.

Commission payments to agents were allowable as business expenditure where they were intrinsically linked to commission income earned from pharmaceutical companies for facilitating marketing and sales. The disallowance based on an assumption that payments related to direct sales to Government hospitals lacked factual support. Recipient details, tax deduction at source, banking-channel payments and recipients' income-tax returns established the identity of recipients, genuineness of payments and business purpose. With no evidence of fictitious payments, non-existent recipients or diversion back to the assessee, the expenditure satisfied the wholly and exclusively business-purpose test and the disallowance was deleted.

Section 87A does not expressly bar rebate against tax payable on short-term capital gains from listed equity shares taxed at the special rate under section 111A. Applying a plain reading of both provisions and following the cited Tribunal precedent, rebate under section 87A is available in respect of such tax liability. Denial of the claimed rebate was therefore unsustainable, and the Assessing Officers were directed to grant it.

Brought-forward unabsorbed depreciation is added to current-year depreciation and retains the character of depreciation, allowing set-off against income under other taxable heads. Its availability does not depend on the existence of positive business income. Accordingly, unabsorbed depreciation may be set off against income from house property, consistent with the principle that it can be carried forward and adjusted against other taxable income.

Employee-welfare payments to educational institutions and club expenditure were treated as business expenditure where incurred wholly and exclusively for business purposes. Enabling-facility costs were characterised as revenue expenditure because no capital asset was acquired. Receipts directly connected with setting up a plant were treated as capital receipts reducible from capital work-in-progress. Depreciation on business vehicles and temporary structures was allowed, while a challenge based on additional depreciation was treated as misconceived because the relief concerned consequential differential depreciation. Bad debts, advances and claims written off were allowable. Premium amortisation on foreign-exchange forward contracts used fo.....

Profits from an eligible windmill unit's electricity transferred for captive consumption qualify for deduction under section 80IA. The profit must be computed using the rate charged by the Electricity Board to consumers, rather than the lower rate paid by the Board to generating companies. Payments were not liable to disallowance merely because payees could not be produced after a substantial lapse of time or because expenditure had increased over earlier years. The nature of payees, including labourers, contractors and job workers, and the fact that several payments were below the tax-deduction threshold, precluded treatment of the payments as unexplained. Deduction for captive wind-generated electricity and the payment claims were consequently accepted.

Indexed cost of improvement claimed on flats received under a joint development arrangement requires evidence of actual improvement works and related payments. Construction costs were contractually borne by the developer, and the flats were sold in the semi-furnished condition received from the developer. Quotations and estimates for proposed additional work did not establish material purchases, labour payments, or execution of improvements. The NALA component was also unsupported. Consequently, the claimed indexed cost of improvement was disallowed, and the appeal was dismissed.

Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.

Section 110 distinguishes goods seized for confiscation from documents or things retained as useful or relevant to Customs Act proceedings. The six-month notice period applies to goods seized under Section 110(1), but not to currency treated as a "thing" under Section 110(3) when retained as evidence in an investigation into fraudulent amnesty claims, suspected hawala transactions, illegal gratification, or related offences. Currency is treated as goods where it is itself the subject of a customs violation, such as undeclared cross-border carriage. The return direction was set aside, and the currency was to be deposited in an interest-bearing nationalised-bank scheme pending investigation.

Unjust enrichment does not bar a customs-duty refund where evidence establishes that the duty incidence was not passed to buyers. A Chartered Accountant certificate, Bills of Entry and sales invoices showing bunker oil was sold below its import value supported non-recovery of even the import cost. Once that material was produced, Revenue needed tangible evidence that buyers bore the duty; recording duty as expenditure in the profit and loss account was insufficient. The High Court upheld the finding that the importer had not passed on the duty incidence, so the refund was properly allowed and no substantial question of law arose.

Customs detention of imported goods is synonymous with seizure once the goods are under Customs control and cannot be cleared without permission; a formal seizure memo is only a later procedural step. The six-month period for issuing a show-cause notice therefore runs from initial detention. Any statutory extension of that period must be granted and communicated before the original period expires; a later extension is without jurisdiction. The time-barred extension was quashed and the goods were directed to be released upon an indemnity bond and proof that any sale would be solely for animal-feed use. Classification, duty liability and the goods' nature remain open for adjudication.