Section 154 permits rectification only of a patent, self-evident mistake apparent from the record and does not permit review of a debatable issue or substitution of one possible view for another. Where a final assessment order expressly applied the India-Mauritius DTAA rate to interest on an income-tax refund, a subsequent rectification could not replace that rate with the domestic-law rate merely by referring to the return of income or the assessment order's lack of detailed discussion. Such reconsideration requires legal examination and falls outside rectification jurisdiction. The treaty rate remained applicable to the refund interest.

Interest on NRE deposits may qualify for exemption under Section 10(4)(ii) even where the individual is resident in India, if the RBI permits continued maintenance of the NRE account. The provision and its proviso prescribe alternative eligibility conditions: residence outside India under the foreign-exchange framework, or RBI permission to maintain the account. Residential status alone does not determine entitlement. Eligibility requires verification of whether the deposits could lawfully continue under the applicable RBI/FEMA framework after the change in residential status. The exemption claim was remitted for limited fresh verification on this issue.

Material non-compliance before the assessing and first appellate authorities warranted a fresh opportunity to substantiate objections and supporting evidence in reassessment proceedings. The first appellate order was set aside and the matter remitted to the Assessing Officer for de novo reassessment after providing the assessee a reasonable opportunity of hearing. The operative principle is that where non-compliance prevents adjudication of tax claims on evidence, a de novo assessment may be directed to preserve principles of natural justice and fair play.

Outright assignment of trademark ownership for lump-sum consideration constitutes acquisition of a capital asset, not royalty for use of intellectual-property rights. Where the transferor's ownership, the rights assigned, commercial terms and tax residency are supported by the agreement and related materials, the remittance is not chargeable to tax in India as royalty. Tax withholding on foreign remittances applies only where the payment is chargeable to tax in India; consequently, no tax-deduction obligation arises and the payer cannot be treated as an assessee in default. The related demand for tax and interest is deleted.

A delayed conveyance fulfilling a promoter's pre-existing statutory and contractual obligation does not constitute a fresh receipt of immovable property for inadequate consideration under section 56(2)(x). Where flat purchasers and the co-operative society had long possessed, occupied and beneficially enjoyed the completed building, the subsequent conveyance merely regularised and perfected legal title by transferring outstanding reversionary and leasehold interests. Settlement consideration paid to resolve intervening disputes, without evidence of unaccounted consideration, a colourable arrangement, or receipt of commercially distinct property in the relevant year, does not make the stamp duty value differential taxable as income.

Professional income must be assessed on a net-income basis and cannot automatically equal gross professional receipts merely because no return was filed or assessment notices were not complied with. Although subsequent-year acceptance of presumptive taxation under Section 44ADA does not independently establish eligibility for the year concerned, it may support the reasonableness of an income estimate where the profession continued without material change. The offer of 50% of receipts as income, tax payment on that basis, and consistent subsequent-year acceptance supported assessment of professional income at 50% of gross receipts.

Cash deposits during demonetisation, where linked to cash sales already recorded in business results, should not be treated as unexplained cash credit when purchases, stock-in-trade and sales remain undisputed. In a trading business, accepted purchases reasonably support corresponding sales. Increased bank deposits may also reflect the inability to use demonetised currency for cash purchases or expenditure, requiring available cash to be deposited. As the profit embedded in those sales has already been offered to tax, assessing the sale proceeds again as unexplained income would result in double taxation. The addition was therefore deleted.

Interest received from loans advanced to companies is taxable under Income from Other Sources where no agency or management contract, or termination or modification of such contract, supports assessment under Section 28(ii)(a). Although lending may be viewed as an adventure in the nature of trade, the stated basis of assessment cannot be replaced at the appellate stage with a different general basis under Section 28. Interest paid on borrowed funds used to make the interest-bearing advances is deductible under Section 57(iii) when a reasonable and proximate nexus with the income earned is established. The Explanation to Section 37(1) does not govern expenditure once the related income is assessed under Income from Other Sources.

Stamp-duty payment is not unexplained investment under Section 69 where the assessee substantiates its source through funds received from a father-in-law. The father-in-law's income-tax return established identity and financial capacity, while the supporting material on creditworthiness was neither disputed nor independently discredited. The explanation for the payment source was therefore sufficiently supported, precluding an addition as unexplained investment.

Properties devolving on a beneficiary upon dissolution of a family trust fall within succession, inheritance or devolution under Section 49(1)(iii)(a). Where acquisition cost is determined by reference to the previous owner, the previous owner's holding period must be included in determining whether the asset is long-term under Explanation 1(b) to Section 2(42A). The same deeming framework applies to indexed cost under Section 48, permitting indexation from the year in which the previous owner first held the property. Accordingly, sale gains are treated as long-term capital gains rather than short-term gains.

Depreciation on goodwill arising from amalgamation, and on brands and trade names transferred through demerger, was treated as allowable where consistent prior treatment applied and no distinguishing facts existed. For captive-power inter-unit electricity transfers, market value was the price paid by the recipient manufacturing unit for open-market electricity, rather than the generator-to-distributor tariff. Steam transferred from an eligible captive-power unit to a non-eligible unit could not be assigned nil value merely because it was a by-product; arm's length valuation may rely on reliable external market comparables rather than internal cost. The disallowances and transfer-pricing adjustments were deleted.

Unexplained cash credits described as advances against future sales require independent evidence of the customers' identity, creditworthiness and the genuineness of the transactions; self-maintained ledgers and matching subsequent sales entries do not establish the original credits. The addition was therefore sustained. Where no binding jurisdictional or Supreme Court authority resolves divergent interpretations of a taxing amendment, the interpretation favourable to the assessee applies. The enhanced tax rate under amended section 115BBE was prospective from assessment year 2018-19 and did not apply to assessment year 2017-18; the sustained addition was taxable at the pre-amendment rate.

Reassessment notices issued beyond four years under the pre-2021 regime could be sanctioned by any authority specified in Section 151(1), including the Principal Commissioner; exclusive approval by the Principal Chief Commissioner was not required. Valid jurisdiction nevertheless required recorded reasons showing a bona fide belief of escaped income and meaningful statutory satisfaction. Incorrect PAN details, the false assertion that no return was filed, absence of a link between reported transactions and escaped taxable income, failure to quantify escaped income at the statutory threshold, and an approval proposal repeating those defects demonstrated invalid jurisdiction. The reassessment notice, consequential reassessment and additions were therefore quashed.

Agricultural-land exclusion from capital gains depends on the land's recorded status, contractual description, actual use and intended use at transfer. Land described in registered instruments as industrial-purpose, recorded as uncultivated and acquired for non-agricultural use may be treated as a capital asset rather than excluded agricultural land. Reinvestment relief under Section 54B requires fulfilment of the prescribed agricultural-use conditions, including use of the transferred land for agriculture during the relevant preceding period. An unchallenged revision order cannot be collaterally contested in proceedings concerning the consequential assessment.

Deduction of cost of funds and related expenditure claimed by a co-operative society was remitted for fresh adjudication after the disallowance was considered against applicable precedent on deposits. The intimation, assessment and penalty orders were quashed because the taxpayer had not responded to notices due to the stated failure of its former tax practitioner. The taxpayer may file objections and respond to the notice issued under the Income-tax Act, while all merits-based contentions remain open for reconsideration.

Preliminary reassessment measures under Sections 148A and 148 are ordinarily not subject to writ challenge before reassessment is completed where the statutory process permits the assessee to raise factual and jurisdictional objections before the Assessing Officer and appellate authorities. Notices, preliminary orders and reassessment notices do not themselves determine tax liability or preclude objections on the applicability of Section 152(3) or approval under Section 151. Threshold intervention under Article 226 is confined to exceptional situations involving total lack of jurisdiction or a patent breach of a mandatory precondition; objections requiring examination of underlying information or search material should be pursued through the reassessment mechanism.

Consequential refund interest required computation after appellate effect orders where the claimed period exceeded the prescribed time for giving effect. The Assessing Officer was required to compute interest under Section 244A(1A), verify whether TDS credit for Assessment Year 2014-15 matched Form 26AS, and grant consequential refund interest under Section 244A(1) if a short credit or short grant was established. Further directions remained pending after verification and computation.

Reassessment notices alleging undisclosed interest on capital and partner remuneration were invalid where the partnership deeds made such payments contingent on mutual agreement rather than mandatory. The amended deed expressly provided that no interest on partners' capital was payable, and no material established actual receipt of interest or remuneration. Treating amounts as necessarily payable merely because earlier deed clauses contemplated them was erroneous. The reopening basis, also found legally unsustainable in the firm's assessments, lacked jurisdiction; the reassessment notices were quashed.

Reassessment based on an alleged incorrect loss computation after a share split is impermissible where the original scrutiny assessment examined the same share transactions, valuation, purchase and sale details, capital gain or loss, and supporting records. Complete transaction, allotment and banking evidence had been furnished, and the reopening reasons identified neither fresh tangible material nor any failure to disclose material facts. Revisiting the tax effect of a 1:10 share split on previously scrutinised transactions constitutes a change of opinion. Reassessment requires fresh tangible material indicating escaped income and, where applicable, a failure of full and true disclosure.

Actuarial-deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions because they remedy funding shortfalls between fund assets and actuarial liabilities. Rule 87 and Rule 103 annual ceilings do not restrict such deficit funding, and section 36(1)(v) permits contributions to an approved gratuity fund without an additional percentage ceiling while approval remains valid. Employee PF/ESI contributions cannot be disallowed under section 36(1)(va) unless the governing legal regime prescribes a due date; a tax-audit software entry or an unrelated provident-fund scheme deadline does not create one.