Share capital supported by share applications, allotment records, confirmations, tax and financial records, bank statements, and account-payee cheque receipts was treated as satisfactorily explained. Investor identity, creditworthiness and transaction genuineness were established; absence of dividends or later dealings did not disprove the investments. An addition could not rest substantially on a retracted third-party statement where cross-examination was denied and no independent enquiry was made from investors or subsequent shareholders. Reassessment based on investigation information identifying alleged accommodation-entry investments was valid because it constituted tangible material for a prima facie belief of income escaping assessment, without requiring conclusive proof at reopening.

Section 14A read with Rule 8D does not apply to a life insurance company because its income is computed under the special regime governing insurance businesses. Consistent coordinate-bench decisions in the taxpayer's earlier assessment years had applied this principle, and no contrary decision was identified. The resulting effect is that expenditure disallowance relating to exempt income is inapplicable to a life insurance company, and the disallowance is deleted.

Adequate opportunity of hearing and independent reasoned appellate findings are required before sustaining additions. Where the assessee could not file submissions and the appellate authority merely repeated the assessing officer's conclusions without addressing the challenges or providing reasons, the appellate order is unsustainable. The matter must be reconsidered in accordance with law after granting reasonable opportunity and issuing a speaking order.

Ex parte appellate adjudication confirming an addition based on a presumptive profit rate applied to cash deposits required fresh consideration because the assessee was denied a reasonable opportunity to present the case. Although the assessee had not complied with notices during assessment and appellate proceedings, the matter was remitted for de novo adjudication after granting a reasonable hearing. No view was expressed on the merits of the addition, leaving them open for reconsideration.

Registration under Section 12A(1)(ac)(iii) requires reconsideration where refusal resulted from non-submission of explanations and documents concerning a trust's objects, and the omission was attributed to the tax professional. Fresh determination must consider the supporting material and provide a reasonable opportunity of hearing. Approval under Section 80G, denied solely because registration under Section 12AB was refused, must also be reconsidered because it is consequential upon the registration determination and applicable exemption conditions. Both the registration and donor-tax-benefit approval applications require fresh adjudication.

Satisfactorily explained and unopposed delay in filing an appeal should be condoned where refusal would defeat substantial justice on a technical ground. Cash deposits made during demonetisation cannot sustain an unexplained-money addition without verification under applicable CBDT instructions and circulars. Verification must examine the claimed sources of deposits, including PAN and KYC particulars of depositors where relevant. The assessment of demonetisation-period cash deposits requires reconsideration after prescribed verification and an adequate opportunity of hearing.

Penalty under section 271(1)(c) cannot be sustained where the notice under section 274 fails to specify whether the charge is concealment of income or furnishing inaccurate particulars. Initiation for furnishing inaccurate particulars followed by imposition for concealment demonstrates inconsistency in the charge. Penalty proceedings are separate from assessment proceedings, requiring the statutory notice itself to communicate the precise allegation and exclude the inapplicable limb. An omnibus notice indicates non-application of mind, and ambiguity in a penal provision or breach of the mandatory notice requirement operates in favour of the assessee. The defective notice renders the penalty proceedings void from inception.

Cash deposits during the demonetisation period cannot be treated wholly as unexplained money under Section 69A where records support their source as business receipts. Deposits in the same bank account had been accepted as business-sourced outside the demonetisation period, while VAT returns and a business licence substantiated the existence and turnover of a proprietary seeds and fertilisers business. As no income-tax return had been filed, taxable income from the disclosed turnover was determined under the presumptive taxation framework in Section 44AD at 8% of turnover. The addition was consequently restricted to estimated net profit rather than the full deposits.

Revisionary jurisdiction under Section 263 validly applies where the Assessing Officer makes no enquiry into the genuineness of claimed truck expenses. Internal communications between the Assessing Officer and the Principal Commissioner do not invalidate the revision where the Principal Commissioner independently follows the prescribed process and identifies the lack of verification. Failure to conduct such enquiry renders the assessment order erroneous and prejudicial to the interests of the Revenue under Explanation 2 to Section 263. The assessment may therefore be set aside through revisionary action.

Delayed deposit of employees' provident fund and ESI contributions requires factual verification where payment delay is attributed to government-server failure, incorrect challan stamping, or circumstances beyond the assessee's control. The claims must be examined under the governing law on delayed employees' contributions after providing the assessee an adequate opportunity to substantiate them. The related additions were remitted for fresh verification.

Reopening of a completed assessment is invalid where the assessee disclosed all land-purchase documents and information during the original scrutiny assessment, and the Revenue identifies neither withheld material facts nor fresh material undermining that disclosure. Reliance on a statement by the seller's son, without a demonstrated connection to the sale deed and without effective cross-examination for the assessee, could not support reassessment. The reassessment was therefore quashed.

Agricultural activities on owned and leased land, including strawberry cultivation, supported the character of produce-sale receipts as agricultural income, although cash receipts required substantiation. Reliance on an undisclosed Tehsildar report prevented effective rebuttal and raised natural justice concerns. On a best-judgment basis, 80% of cash agricultural income was accepted and the remaining 20% treated as taxable income from other sources. Cash deposits linked to registered sale deeds for family agricultural land established a transaction nexus, but inconsistent purchaser responses left advances unexplained. After reducing available agricultural cash income, only an estimated balance was retained under Section 69, requiring recomputation of taxable income.

Cash deposits following the sale of agricultural land were supported by the sale deed and temporal proximity, creating an evidentiary presumption that they represented sale consideration and advances. The assessee nevertheless did not establish the source to the lower authorities' complete satisfaction. Balancing the available evidence against the burden of proof, only a lump-sum addition was considered warranted, and the unexplained cash-deposit addition was restricted substantially.

Unexplained cash deposits were substantially linked to the cash component of consideration from the sale of two properties. Although the sales supported the source of the deposits, the evidence did not establish the full amount to the satisfaction of the lower authorities. The unexplained-cash addition was therefore substantially restricted, with only a limited portion of the deposits retained as unexplained income and corresponding relief granted to the assessee.

Income already deducted and assessed in the preceding assessment year cannot be assessed again in the subsequent assessment year, as this would result in double addition. The addition made for the later assessment year was therefore deleted because the same amount had already been brought to tax in the earlier year.

Section 153C requires a satisfaction note based on seized material that bears on the assessee's income for each relevant assessment year. Where the same material is invoked for multiple years, the note must identify the material and demonstrate its incriminating nexus with escaped income for every year concerned. A consolidated note referring generally to unrecorded cash transactions, without year-wise identification of seized material or linkage to escaped income, fails the statutory requirement. Such satisfaction is arbitrary, rendering the resulting section 153C assessments legally invalid and liable to be quashed.

Cash deposits were treated as satisfactorily explained where cash-flow statements, bank summaries and passbook entries established sufficient opening cash balances and cash receipts for each relevant assessment year. In the absence of material discrediting the stated sources or showing concealment, the deposits could not be characterised as unexplained money. The proposed addition was therefore not sustainable, and the issue was resolved in favour of the assessee.

Interest disallowance based on alleged non-genuine loans was premature because the question whether the principal loans were accommodation entries remained pending for the years in which those loans were obtained. Unclaimed interest expenditure was permitted to be set off against the interest disallowed on those loans. Consequently, the interest disallowance was restricted after allowing the set-off.

Section 263 revision cannot disturb an assessment allowing Section 54F deduction where the Assessing Officer conducted detailed enquiry and adopted a plausible view. Six flats acquired under one agreement across three floors, internally interconnected and used as a triplex residence, may constitute one residential house because Section 54F does not prescribe a particular physical configuration. A different view based on the same examined material does not establish that the assessment was erroneous and prejudicial to the interests of the Revenue. The revisionary order was therefore invalid, and the Section 54F deduction remained allowable.

Penalties for underreporting income due to misreporting cannot be sustained where the penalty proceedings fail to identify the specific statutory limb of misreporting. Excess deductions and house-property losses claimed on tax advice were corrected by repayment of the excess refund with interest before reassessment notices, and revised returns reporting correct income were accepted. Coordinate-bench reasoning treats non-specification of the relevant misreporting clause as fatal, particularly where correct tax is paid before Revenue detection. The penalties under section 270A were therefore directed to be deleted.