Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer has examined unsecured loans, obtained supporting material and adopted a plausible view, revision cannot rest merely on a preference for further inquiry or a different view; inadequate inquiry alone is insufficient. For alleged suppression of business receipts, the revisional authority must conduct necessary independent inquiry and identify defects in the assessee's reconciliation before directing fresh examination. Without a definite finding of error and prejudice, revision becomes an impermissible fishing or roving inquiry. The stated revision grounds were therefore invalid.

Overseas NRI Desk costs for internal audit, financial control, information technology, human resources, operations, rent, maintenance, depreciation and advertising are characterised as executive and general administration expenses of overseas banking operations. Although connected with Indian business operations, such costs fall within the specified categories of head office expenditure rather than direct business expenditure. Their deduction is therefore restricted to the statutory ceiling applicable to head office expenditure and cannot be claimed in full.

Cash-method accounting permits interest and dividend income to be taxed only on actual receipt where that method has been consistently followed; rejection of books does not justify presumed accrual. Unsupported additions for money-market and share-market oversold positions, trading profits, assumed interest, and estimated income fail where delivery, ownership, receipt, or third-party evidence is not established and documentary explanations remain unrebutted. Disclosed banking transactions cannot be treated as unexplained without substantiated contrary material, while bank credits remain taxable where their nature and source are not explained. Opening balances of loans and advances are not assessable in the relevant year; remaining balances require verification. Assessed income may be telescoped against unexplained investment or expenditure, subject to consequential computation and statutory relief.

Business expenditure remains deductible where contractual arrangements and contemporaneous material establish that the assessee incurred and bore the cost, even though the principal work was subcontracted. Transportation expenses incurred for earthwork and movement before the site was handed to the subcontractor were treated as the assessee's responsibility under the original arrangement later documented in a memorandum of understanding. Labour welfare cess and copy charges deducted from the assessee's bills under tender terms were likewise treated as expenses borne by the assessee. No duplicate claim by the subcontractor or dispute over genuineness arose.

Deduction under Section 80P(2)(a)(i), allowed after scrutiny assessment by treating interest income as business income attributable to a co-operative society's activities, cannot be withdrawn through rectification where reconsideration of the income's nature and deductibility is required. Section 154 applies only to errors apparent from the record and cannot resolve a debatable issue. Authorities concerning deduction under Section 80P(2)(d) do not justify reversal in rectification proceedings of a deduction allowed under Section 80P(2)(a)(i). The rectification and appellate orders reversing the deduction were set aside.

Additional evidence concerning identity, creditworthiness and genuineness of non-resident share subscriptions must be examined under Rule 46A through the Assessing Officer's comments in a remand report. The absence of an assessment under section 144 does not remove this requirement. Bank statements and e-KYC records required factual verification, while the DCF valuation report and underlying projections relevant to alleged excess share premium also required examination on complete material after adequate opportunity. Additions for unexplained share capital and share premium, and for excess premium, were set aside for fresh appellate adjudication following a remand report and effective opportunity to the assessee.

Transfer pricing treatment of zero-coupon non-convertible debentures must remain consistent where the contractual terms, material facts and associated-enterprise transaction are unchanged. Debentures carrying no periodic interest but providing a holding-period-linked redemption premium had previously been accepted at arm's length without adjustment. Imputing notional interest on a later closing balance that included the earlier subscription effectively reversed that accepted treatment without recourse to permissible statutory proceedings. Although strict res judicata does not apply to assessment proceedings, consistency is required on unchanged facts. The notional-interest adjustment was therefore deleted.

Enhancement of an assessment by the first appellate authority, including on a fresh issue or new source of income, requires prior compliance with the mandatory reasonable-opportunity requirement under Section 251(2) of the Income-tax Act, 1961. Disallowance of short-term capital loss without giving the assessee an opportunity to show cause cannot be sustained. The enhancement was set aside and remanded for fresh adjudication after adequate opportunity of hearing.

Failure to obtain a tax audit does not attract penalty where turnover remains below the enhanced audit threshold and the prescribed cash-receipt and cash-payment conditions are satisfied. Reconciliation of operating revenue with bank credits may account for differences arising from GST and tax deducted at source. Financial statements, cash records, bank statements and audit material indicating no cash receipts, cash payments, or opening or closing cash-in-hand support application of the enhanced threshold. Consequently, the tax-audit requirement does not apply and penalty for non-compliance is not leviable.

Adequate opportunity of hearing was not provided where the assessment followed shortly after an unanswered show-cause notice without a further opportunity to respond. Although rejection of the books of account was not considered defective, the assessment requires fresh adjudication after the assessee receives adequate and reasonable hearing. The merits of book rejection and income estimation remain open for independent consideration upon verification of relevant details, clarifications and explanations.

Genuine voluntary contributions received with specific donor directions to form part of an educational institution's corpus retain their capital character and are not taxable merely because the institution claims exemption under Section 10(23C)(vi) rather than Section 11. Donor identity, banking-channel receipt, confirmation and an express corpus direction distinguish such receipts from ordinary voluntary contributions available for application toward institutional objects. The absence of an identically worded corpus exclusion under Section 10(23C)(vi) during the relevant year does not change the legal character of genuine corpus contributions; subsequent clarification under that provision supports this treatment.

Income surrendered during a survey and included in the return cannot be taxed at the special rate under section 115BBE merely because its source is not precisely explained. Section 115BBE applies only to income properly falling within the deeming provisions for unexplained credits, investments, money, expenditure or related items. The relevant deeming provision must be specifically identified, and its foundational conditions must be established. Where no such provision is invoked and no findings support its application, surrendered income remains taxable at the normal applicable rate.

Agricultural receipts from date cultivation cannot be assessed as income from other sources merely because estimated yield exceeds declared sales where the agricultural land, plantation, operations and sale rate are accepted. Such an addition requires evidence that the declared quantity was not produced or sold, or that receipts arose from a non-agricultural source. Likewise, agricultural expenditure cannot be increased through an ad hoc percentage estimate without identifying false or inadmissible expenses or relying on comparable data, expert material or another cogent basis. Unsupported estimates of yield or expenditure do not displace recorded agricultural receipts and accounts; consequential interest must be recomputed.

For Assessment Year 2024-25, the section 87A income-tax rebate is available against tax payable on short-term capital gains taxable under section 111A where the taxpayer has opted for the section 115BAC tax regime. This position follows consistent coordinate Tribunal decisions allowing the rebate, with no contrary High Court or Supreme Court ruling identified. The rebate consequently reduces tax computed on such short-term capital gains for eligible taxpayers under the new tax regime.

Cash consideration receivable in relation to transfer of immovable property falls within the definition of a specified sum under section 269SS, rather than section 269ST. The restriction on such receipts applies only from its effective date. Penalty under section 271D cannot be imposed for an assessment year in which no relevant cash consideration was received, even if the transaction otherwise falls within section 269SS. Receipts relating partly to a period before the restriction became effective and to an earlier assessment year cannot support a penalty for a later assessment year; the penalty is therefore invalid.

Subletting charges paid to MIDC as a mandatory lease condition for earning rental income are deductible in computing income from house property. Where subletting is permitted only upon payment of those charges, they constitute an integral cost of earning the rental income and rental receipts must be computed on a net basis after reducing that cost. The statutory deduction under Section 24(a) does not preclude deduction of mandatory subletting charges in arriving at taxable rental income. Principles applicable to exemption notifications do not govern this computation, and prior acceptance of the claim supports consistency.

Transfer-pricing benchmarking for cross-border loans may require LIBOR plus an appropriate basis-point spread, with LIBOR plus 200 basis points treated as the applicable arm's-length rate. Corporate-guarantee pricing was benchmarked at 1% based on inter-group guarantee rates and the taxpayer's charging pattern. No notional interest adjustment was warranted on delayed associated-enterprise receivables where comparable delayed payments from non-associated enterprises were interest-free. Brought-forward losses and unabsorbed depreciation require verification before consequential allowance in accordance with law.

Penalty for failure to furnish transfer-pricing documentation under Section 271G requires identified information or documents to be specifically requisitioned under Section 92D(3). An ambiguous penalty notice that does not identify the allegedly missing material cannot establish this prerequisite. Notices issued under Section 92CA(2) do not substitute for a statutory requisition under Section 92D(3) or prove non-production within the prescribed period. Where the taxpayer furnishes the transfer-pricing study report in response to a specific Section 92D(3) notice within time, penalty is not sustainable. Because Section 271G is penal in nature, its procedural requirements require strict compliance.

Penalty for misreported income requires examination of the statutory exclusion for a bona fide explanation and full disclosure of material facts. Imposition at the enhanced rate requires recorded reasons, and the appellate authority must determine whether the explanation for non-filing of a return despite tax deduction at source satisfies the conditions for exclusion. Where that assessment is absent, the penalty cannot be sustained; the matter requires reconsideration through a reasoned speaking order.

Delayed filing of the audit report in Form No. 10B is a directory procedural lapse where the report accompanies the income-tax return and is filed before processing under Section 143(1). In those circumstances, delay does not defeat substantive entitlement to charitable exemption under Section 11. Charitable exemption should therefore not be denied solely because Form No. 10B was filed after the prescribed deadline, provided it was filed with the return before the intimation was issued.