Section 56(2)(x) applies only where an assessee receives land, a building, or an independently identifiable immovable-property right during the relevant year. A supplementary agreement modifying building plans under a pre-existing property arrangement does not trigger the provision where it neither transfers fresh immovable property nor creates an additional independent proprietary right. Absence of additional consideration supported the conclusion that no qualifying receipt occurred. Stamp duty valuation is relevant only after receipt of qualifying immovable property is established and cannot independently bring the transaction within section 56(2)(x). Accordingly, the addition based solely on the supplementary agreement's stamp duty valuation was deleted.

Section 68 requires identification of a specific unexplained credit; reconciled capital movements and cash deposits recorded in audited accounts from disclosed professional receipts cannot be treated as unexplained without identified defects or cash deficits. Property received on partition of a Hindu undivided family takes the previous owner's cost and holding period, allowing indexed cost computation. Resulting eligible long-term capital loss may be set off against qualifying long-term capital gains and carried forward subject to statutory restrictions. Registered sale consideration received through banking channels, supported by the conveyance and tax-deduction trail and accepted for capital-gains computation, should not also be assessed as an unexplained credit absent evidence of a sham or recycled funds.

Sponsorship receipts from a women's marathon integrally connected with charitable objects of health, fitness, awareness and empowerment do not constitute trade, commerce or business merely because sponsors obtain promotional benefits or the event generates substantial receipts or surplus. Commerciality depends on the activity's intrinsic nature, purpose and manner, not the sponsors' accounting treatment or receipt quantum. The proviso to section 2(15) and section 13(8) therefore do not apply where no independent commercial undertaking or distinct commercial services exist. Furnishing Form 10BB instead of Form 10B is a curable procedural defect where accounts were audited before filing, valid registration existed, and Form 10B was submitted during assessment; it does not defeat exemption under section 11.

Unexplained-credit, unexplained-expenditure and unexplained-money additions cannot rest on general investigation inputs or presumptions where transactions are supported by lender confirmations, audited financial statements, tax records, bank statements, ledgers, TDS records and repayment evidence. Identifiable corporate lenders with disclosed financial capacity and business operations support the genuineness of banking-channel loans. Interest on established genuine borrowings is not unexplained expenditure. Presumed accommodation-entry commission requires evidence of cash outflow or payment. Alleged bogus purchases require material contradicting invoices, transport records, e-way bills, ledgers and banking payments. Repayment of documented opening loan balances through banking channels does not itself establish ownership of unexplained money.

Deemed rental value of unsold flats held as stock-in-trade was not assessable for Assessment Year 2017-18. Section 23(5), which expressly provides for taxation of deemed rental income from unsold stock-in-trade, took effect from Assessment Year 2018-19 and did not apply retrospectively. Where High Court views conflicted, the interpretation favourable to the assessee applied. Accordingly, the notional rental-income addition for unsold flats retained as stock-in-trade for Assessment Year 2017-18 was deleted.

Reassessment notices issued more than three years after the end of the relevant assessment year require prior sanction from the higher authorities expressly specified in section 151(ii). Approval by a Principal Commissioner, rather than the prescribed Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General, fails this jurisdictional condition. Consequently, the notice under section 148 and all consequential reassessment proceedings are void from inception. A delay caused by an accountant's absence due to a family medical emergency may be condoned where supported by an affidavit and shown to be unintentional and beyond the assessee's control.

Section 80P(2)(d) permits a co-operative housing society to claim deduction for interest earned from investments with co-operative banks. The term "investment" is not limited to fixed deposits and includes funds kept in savings accounts. Interest from savings accounts maintained with co-operative banks therefore qualifies for deduction, as such banks are treated as co-operative societies for this purpose. The deduction applies to interest income earned from both deposits and savings accounts with co-operative banks.

Property-purchase additions treated as unexplained money were unsustainable where agreements to sell, cash-flow statements corroborated by bank records, family income-tax returns, loan confirmations, sale deeds, and booking and payment records established the sources and legitimacy of the transactions. The documented evidence sufficiently explained the funds used to acquire the two properties, requiring deletion of the addition.

Interest income earned by a co-operative housing society from deposits with co-operative banks qualifies for deduction under Section 80P(2)(d). The provision permits deduction of interest or dividend derived by a co-operative society from investments with another co-operative society, and co-operative banks are treated as co-operative societies for this purpose. The exclusion in Section 80P(4), applicable to co-operative banks, does not bar an assessee co-operative society from claiming deduction on interest received from such banks.

Unexplained expenditure under section 69C requires failure to explain the source of expenditure or an explanation of that source that is unsatisfactory. Payments made through bearer cheques from the assessee's recorded bank accounts cannot be added merely because they exceed the purchases and expenses claimed, unless the source of those payments is found unexplained. An inability to establish the purpose or destination of payments does not satisfy the statutory requirement concerning their source. The addition was therefore unsustainable and liable to be deleted.

Rule 68B's 2019 extension of the period for sale of attached immovable property applies to recovery claims still within the earlier limitation period but cannot revive claims already time-barred. Recovery-sale proceedings for the earlier assessment years were therefore barred, while those for later years remained timely because the amended period applied before expiry. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial; consequently, the Supreme Court's COVID-19 limitation exclusion applied. For unappealed demands, Rule 68B finality arises only after expiry of the demand-payment and ordinary appeal periods, preserving the later recovery proceedings and preventing release of the attachment.

A writ challenge to a Tribunal recall order does not remain maintainable once the Tribunal passes a final order pursuant to that recall. The recall order merges into, and no longer exists independently from, the final order. Where the final order is separately challenged through the statutory tax appeal remedy, the antecedent recall order cannot be challenged independently by writ petition. The challenge against the assessee therefore failed on maintainability.

Section 11(1)(d) exempts voluntary contributions only where a donor specifically directs in writing that they form part of the corpus. Interest earned on fixed deposits held in a charitable trust's own name arises from its investments and remains revenue income unless a donor expressly directs that such interest be treated as corpus. Donor permission to use refunded funds for self-help group or micro-credit programmes does not amount to a corpus direction for deposit interest. Earmarking funds for programme purposes constitutes application of income after accrual, not diversion at source. Claiming tax-deducted-at-source credit on the interest is inconsistent with excluding it from receipts.

Foreign investment was treated as duly explained where documentary evidence established the investors' registration and tax status, the investment-cum-collaboration agreement, restructuring, inward remittances, audited financial statements, and issuance of shares and compulsorily convertible debentures. The transfer-pricing report contained no adverse finding. Concurrent findings accepting the investors' identity, creditworthiness and the genuineness of the transactions cannot be disturbed without demonstrated perversity. Failure by the assessing authority to objectively address the assessee's supporting material also breached procedural fairness. Consequently, no addition for unexplained foreign investment under Section 68 was sustainable and no substantial question of law arose.

Actuarially backed ad hoc contributions made to remedy an established deficit in an approved superannuation fund are distinguished from ordinary annual contributions and initial contributions. Their legal character depends on their deficit-remedying purpose, including liabilities arising from earlier funding constraints, rather than the period over which the deficit arose. The annual ceiling under Rule 87 does not apply to such actuarially necessary funding, as applying it could impair fund solvency and conflict with the deduction available for contributions to approved funds under section 36(1)(iv). A reasoned application of governing precedents supports deletion of a disallowance and does not render that determination arbitrary or perverse.

Actuarially necessary contributions made to cure deficits in approved superannuation funds are distinguished from ordinary annual or initial contributions and are not subject to the Rule 87 ceiling. Applying that ceiling to deficit funding would impair fund solvency and conflict with the deduction available for approved superannuation-fund contributions. Contributions that bridge an actuarial shortfall in an approved gratuity fund are likewise not subject to the Rule 103 ceiling. Where approval of the gratuity fund remains in force, the Assessing Officer cannot revisit that approval or use Rule 103 to disallow actuarially required funding. Such deductions remain available where payments cure approved employee-benefit fund deficits.

Actuarially determined ad hoc contributions made to eliminate accumulated funding deficits in an approved superannuation fund are not ordinary annual contributions subject to the Rule 87 ceiling. Their character depends on the purpose of curing the gap between fund assets and actuarial liabilities, including deficits carried from earlier years, rather than on whether deficit funding recurs. Such payments are also distinct from initial contributions. Applying the annual ceiling to necessary actuarial-deficit funding would undermine fund solvency and conflict with the deduction framework for approved superannuation funds. A reasoned appellate determination based on applicable precedents is not arbitrary or perverse.

Composition eligibility lapses from the day aggregate turnover exceeds the prescribed threshold, requiring payment of tax under the regular scheme on subsequent supplies. Where turnover calculations have excluded accepted e-way bill errors, the remaining admitted turnover determines the lapse; input-tax credit remains unaddressed without a substantiated claim. Post-lapse invoice values must be treated as tax-inclusive where the composition taxpayer did not collect tax separately. Rule 35 requires extraction of the tax component from the total consideration, even if cum-tax treatment was not expressly claimed earlier. Tax, interest and penalty require redetermination on that cum-tax basis.

Rule 86A of the CGST Rules permits temporary restriction only of input tax credit available in the Electronic Credit Ledger when the prescribed officer records reasons to believe that the credit was fraudulently availed or is ineligible. Credit availability at the time of invocation is a condition precedent. The rule does not authorise departmental debit entries, negative blocking, or restrictions exceeding the ledger balance. Although prior notice is unnecessary for an emergent restriction, recovery of wrongly availed or utilised credit must proceed under the statutory recovery mechanism. Restrictions beyond available credit are invalid.

Delayed GST appeals filed beyond the ordinary and condonable periods under Section 107 may, in peculiar circumstances involving factual questions requiring appellate examination, receive a further opportunity for merits adjudication. The delay was condoned, the dismissal and rectification orders concerning the appeal were quashed, and the appeal was restored for adjudication after adequate hearing.