Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue. Deduction under section 80P(2)(d) on interest from a Regional Rural Bank had been specifically examined and allowed after inquiry, following jurisdictional High Court precedent treating a Regional Rural Bank as a co-operative society through the statutory deeming fiction in the Regional Rural Banks Act, 1976. Section 80P(4) did not displace that precedent. A later contrary coordinate-bench view could neither retrospectively make the assessment erroneous nor override binding High Court authority. Explanation 2 to section 263 did not apply because there was no lack of inquiry; consequently, revision was unsustainable.

Section 69A applies only where jewellery found in possession is not satisfactorily explained. Jewellery within customary family holdings may be assessed with reference to CBDT Instruction No. 1916, while earlier voluntary disclosure can independently support its source. In the absence of material proving exclusive ownership or unexplained acquisition in the relevant year, such jewellery is not taxable as unexplained assets. Section 69B requires evidence that an investment exceeds what is recorded in the books. Stock supported by contemporaneous purchase entries, invoices, banking payments and the actual owner's financial records is explained; valuation differences alone do not establish unrecorded investment without contrary material.

Section 80G(5)(i) permits an institution to establish that its income is not includible in total income through alternative routes: exemption under sections 11 and 12, or coverage under section 10(23C). Registration under section 12AB relates to the sections 11 and 12 route and is not a universal precondition for 80G approval. Where an educational institution claims that its income is covered by section 10(23C)(iiiad), eligibility must be verified under that provision rather than rejected solely for lack of 12AB registration. Approval under section 80G(5) should follow where such coverage is established.

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.