Non-genuine purchases from accommodation-entry providers, where corresponding sales are accepted, warrant taxation of only the embedded profit element rather than the full purchase value. A 15% profit-element addition is identified as consistent with comparable bogus-purchase treatment. Reassessment may be initiated where investigation information links accommodation entries to the taxpayer's purchase transactions and provides prima facie material indicating escaped income. At the reopening stage, the material need not conclusively establish escapement; its sufficiency is not examined once a reason to believe is properly formed and objections have been addressed.

For pre-amendment assessment years, capital gains invested within the prescribed period in more than one residential unit could qualify for residential-property relief. The expression "a residential house" was capable of covering multiple units before the statutory restriction to one residential house took effect from 1 April 2015; that restriction operates prospectively and cannot alone deny relief for earlier years. A reopening challenge based on the absence of a separate speaking order on objections does not arise where the communication contains only factual statements rather than specific, substantive objections to the recorded reopening reasons.

Capital-gains cost of improvement requires capital expenditure that adds to or alters the residential flat and is inseparable from the building. Routine repairs, maintenance, decorative articles, and detachable or movable items do not qualify because they do not change the character of the capital asset. Expenditure on pest control, artwork, upholstery, curtains, furnishings, gym equipment, plants, decor, furniture and related accessories was treated as non-qualifying. Glass and mirror work, kitchen and bathroom items, wallpaper, air-conditioning, home theatre and interior-work expenditure require item-wise verification of invoices, payments and installation evidence before determining allowability.

Income validly accumulated under section 11(2) and subsequently applied to charitable objects does not become specified income taxable under section 115BBI solely because of an inadvertent mismatch between return schedules. Where revised Form 10-BB and return disclosures establish the amount's source, character and charitable application, a reporting omission cannot create a statutory tax charge. Processing under section 143(1) cannot selectively rely on the mismatch while disregarding contemporaneous disclosures demonstrating that the accumulation neither became deemed income nor breached conditions applicable to charitable funds. The proposed adjustment is therefore liable to be deleted.

Fresh assessments required after remand, with reconsideration after giving the taxpayer an opportunity, fall within the limitation framework for fresh assessment or reassessment rather than the separate period for merely giving effect to appellate directions. Unsupported foreign currency may be treated as unexplained money where explanations of its source and purpose are contradictory and lack documentary support, including proof of acquisition from authorised dealers. Foreign-exchange confiscation proceedings concerning unlawful retention do not establish the currency's source for income-tax purposes, and an offsetting expenditure claim does not displace unexplained-money treatment.

Section 249(3) requires a credible, bona fide explanation showing that circumstances beyond the appellant's control prevented timely filing of a first appeal. Voluntarily offering a receipt to tax, accepting the resulting intimation without challenge for about ten years, and later relying on favourable developments concerning the payer's registration do not demonstrate diligence or sufficient cause. Waiting for a favourable legal outcome, misunderstanding the legal position, tracing records, or consulting professionals cannot reopen an assessment accepted after an inordinate delay. The delay was therefore not condonable.

Section 153C requires the assessment block for a non-searched person to be computed from the date on which the jurisdictional Assessing Officer receives the seized books, documents or assets. The first proviso to Section 153C(1) applies this deemed reference date to the six-year and relevant ten-year assessment periods, not merely to abatement. Since the satisfaction and initiation of proceedings occurred in 2022, AYs 2010-11 and 2011-12 fell outside the permissible statutory block. Assessments for those years were therefore beyond jurisdiction under Section 153C.

Reassessment under Sections 147 and 148 cannot rest on information and statements already available and considered in earlier search assessment and revision proceedings. Where an investigation-wing communication merely repackages existing material, it does not provide fresh tangible material for reopening. Failure to address confirmations obtained from the concerned entities before issuing the reopening notice further supports that the action is based on a change of opinion. Approval founded solely on the same old statement, without independent consideration, is mechanical. Such reopening is beyond jurisdiction, requiring deletion of additions made in the reassessment.

TDS credit under section 199 read with Rule 37BA(2) belongs to the person in whose hands the related income is assessable. Where a trust's funds were invested through its trustee, the interest income was offered and assessed in the trust's hands, and tax was deducted in the trustee's PAN, the trust remains the beneficial owner entitled to the credit. The declaration under the proviso to Rule 37BA(2) is procedural and does not defeat that substantive entitlement where the income has been returned to tax and the tax deduction is undisputed.

MEIS duty credit scrips under the Foreign Trade Policy, 2015 constitute taxable revenue receipts from assessment year 2016-17. Applying the purpose test, the rewards offset recurring export-related costs and infrastructural inefficiencies, are linked to export turnover, and need not be used for capital assets; they therefore support the conduct of export business rather than its establishment or expansion. Section 2(24)(xviii) covers governmental assistance by whatever name called and cannot be narrowly restricted through ejusdem generis or noscitur a sociis. MEIS rewards qualify as grants, cash incentives or residuary governmental assistance, while neither statutory exclusion applies.

Further disallowance of expenditure relating to exempt income under Section 14A read with Rule 8D requires examination of the accounts and recorded dissatisfaction with the assessee's suo motu computation. A different computation alone does not meet that statutory condition, so the additional disallowance was deleted. Share premium valuation under Section 56(2)(viib) and Rule 11UA using the discounted cash flow method must be assessed from information and estimates available on the valuation date. Subsequent actual financial results cannot, without a material error in inputs or methodology, justify replacing that valuation with the net asset value method. The excess share-premium addition was therefore deleted.

Revision under Section 263 requires the competent income-tax authority to exercise the power in its authorised statutory capacity. Where an officer formally holding charge as Chief Commissioner acts and signs as Principal Commissioner without express authorisation to perform that authority's functions, the revisionary notice and consequential order lack jurisdiction. Revision also cannot rest on a preference for further inquiry when the Assessing Officer examined property ownership, use and annual letting value, accepted a plausible view, and no specific error causing prejudice to revenue is established. Explanation 2 does not permit revision merely on a change of opinion.

A delayed tax appeal requires sufficient cause for condonation; an unexplained delay unsupported by an application, affidavit, explanation or material prevents admission. An appeal against a company's assessment may be maintained only by the assessee affected by the order or a person duly authorised to represent it. A former director of a struck-off company has no personal right to challenge assessment and appellate orders made against the company where no personal liability, authority to represent the company, or foundational assessment order is shown. Striking-off provisions preserving liabilities do not independently confer locus standi.

Reliable internal uncontrolled comparables should be preferred over external comparables where they more closely match the transaction's terms and credit profile. For fixed-rate masala bonds, bank borrowings of the same enterprise provided an appropriate internal CUP, unlike floating-rate external lending comparables; the interest adjustment was deleted. Operational, technical, knowledge-sharing and systems support received from an associated enterprise were not shareholder activities where business need, actual receipt, costs and mark-up were established. Under the CUP method, an arm's length price cannot be fixed at nil without supporting uncontrolled comparables; the related services adjustment was deleted. Tax deducted at source credit remains subject to verification under law.

The beneficial proviso to section 50C(1) permits use of the stamp valuation applicable when sale consideration was fixed and acted upon, rather than the valuation prevailing at registration, where guideline value later increased. A continuous evidentiary chain comprising statutory rehabilitation, contemporaneous transferor and transferee resolutions, banking-channel advance payments, and sale deeds reflecting identical consideration can establish prior fixation of consideration. A formal bilateral agreement is not indispensable where the parties' conduct conclusively proves that fixation. The differential long-term capital gains addition based on the later stamp valuation was deleted.

External Development Charges paid to Haryana Urban Development Authority were treated as payments subject to tax deduction at source under Section 194C. A deductor cannot be treated as an assessee in default where the payee has filed its return, included the relevant receipts in taxable income, paid the tax due, and the deductor furnishes the prescribed accountant's certificate under the first proviso to Section 201(1). Verification of these conditions is necessary before imposing liability under Sections 201(1) or 201(1A); the matter requires verification by the Assessing Officer.

Consideration for live telecast rights in a composite cricket media-rights agreement is not royalty because a live sporting event is not a pre-existing copyrighted work and no copyright is transferred. Consideration attributable to non-live or repeat telecast rights is royalty, as it relates to the use of copyright. Where tax was required but not deducted, only the royalty component is disallowable under the withholding-tax provisions. Applying the established live-to-non-live viewership ratio, 93% of the payment attributable to live broadcasts is not disallowable, while 7% attributable to non-live broadcasts is royalty and is disallowable.

Section 54F applies only where long-term capital gains arise from transfer of an asset other than a residential house; a transfer of a residential property is therefore governed by Section 54, not Section 54F. Section 54 requires the same assessee who transfers the original residential property to purchase or construct the replacement residential property within the prescribed period. A property bought solely in the spouse's name is treated as acquired by a distinct legal person and cannot be linked to the assessee's sale for the exemption. Consequently, capital gains remain taxable where neither provision's conditions are met.

Disallowance computed under Section 14A read with Rule 8D cannot, merely because it is disallowed for normal tax computation, be added to book profit under Section 115JB. The relevant Explanation permits adjustment only for expenditure relating to exempt income determined under the book-profit computation, and does not import the Section 14A/Rule 8D mechanism. Accordingly, book profit cannot be increased solely by the amount disallowed under Section 14A using Rule 8D.

Eligibility under the Direct Tax Vivad Se Vishwas Scheme, 2024 extends to a person whose writ petition challenging an interest determination and rejection of an interest-waiver application was pending on the specified date. Such a person falls within "appellant", while the challenged interest is treated as disputed interest and tax arrears. FAQ 15 applies only where the waiver application itself remained pending before the competent authority on that date; it does not exclude a pending High Court challenge to a decided waiver application. This interpretation permits settlement of a genuine pending interest dispute.