For reassessment notices for assessment year 2015-16 governed by the pre-1 April 2021 regime, the extended limitation period under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not alter the prescribed sanctioning authority. Section 151(2) required prior satisfaction of the Joint Commissioner before issuing a notice under section 148. Approval by the Principal Commissioner could not replace that statutory requirement. A notice issued without sanction from the competent Joint Commissioner was invalid, rendering the consequential reassessment proceedings and assessment order null and void.

Cash deposits of specified bank notes received from members towards crop and tractor loan recoveries cannot be treated as unexplained cash credits under Section 68 where regularly maintained books, member-wise details and the loan-repayment nexus satisfactorily establish their nature and source. The later restriction on specified bank notes does not itself negate the explained character of recorded credits. Taxing such disclosed gross receipts again as unexplained credits would result in double taxation. The receipts are to be treated as business receipts, with deduction under Section 80P available in accordance with law.

Revision jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue. Absence of enquiry into the actual use of borrowings and the possible capitalisation of related interest can justify fresh examination. Revision cannot, however, direct fishing or roving verification without identifying a specific error causing prejudice. Where the Assessing Officer has examined expenditure records, tax-deduction particulars, contractual materials and treaty applicability, a plausible view reached after enquiry cannot be replaced through revision. Accordingly, fresh examination is confined to the interest-capitalisation issue, while directions concerning tax deduction on payments to Government authorities, miscellaneous expenditure and service-provider charges are unsustainable.

Charitable registration renewal requires verification that any alleged breach of another law concerns legislation applicable to the applicant. Non-registration under the Rajasthan Public Trust Act cannot be treated as material non-compliance where the applicant, including an Urban Improvement Trust, may fall within the statutory exclusion for trusts administered by State-controlled agencies or local authorities. Deficiencies in Form No. 10AB or supporting material that can be cured must be specifically notified, with an effective and reasonable opportunity to provide documents or clarifications. Continuation of registration must then be assessed on complete material after determining the Act's applicability and curing identified defects.

Eligibility for the concessional corporate tax regime under Section 115BAA is examined where Form 10-IC was created and saved on the income-tax portal by the due date but filed late because of a technical glitch. Portal records evidencing a genuine, timely attempt to exercise the option are relevant to the delay. The condonation approach under CBDT Circular No. 6/2022 addresses genuine hardship arising from such technical failures and supports assessment under the concessional regime.

The proviso to Section 12A(1)(ac), effective from 1 October 2024, empowers the Principal Commissioner or Commissioner to condone delay in filing Form No. 10AB for regularisation of provisional registration where reasonable cause is established. An application filed after the prescribed period cannot be rejected solely as time-barred without examining that statutory discretion. A bona fide misunderstanding regarding the duration of provisional registration may require consideration as reasonable cause, although a substantial delay must be specifically assessed by the competent authority. Strict-compliance principles do not override an express statutory power to condone delay.

Section 80G(5B) treats an institution or fund with religious expenditure not exceeding five per cent of its total income during the relevant previous year as eligible for section 80G, notwithstanding religious or religious-cum-charitable objects. Explanation 3 excludes purposes that are wholly or substantially wholly religious from charitable purpose, but does not displace this statutory threshold. Approval cannot be refused solely because of religious objects without verifying actual religious expenditure. Eligibility depends on compliance with the five per cent limit and the remaining statutory conditions.

Cost-to-cost reimbursements received from Indian associated enterprises for third-party event, legal, professional, employee welfare and recruitment expenses were not taxable in India where the underlying activities were performed remotely without employees or personnel being physically present in India. A service permanent establishment under Article 5(2)(l) of the India-USA tax treaty requires services to be furnished or performed in India through employees or other personnel for the stipulated duration. As those cumulative conditions were not met, no service permanent establishment arose and the reimbursements did not constitute income chargeable to tax in India.

Corporate guarantees issued for associated enterprises are treated as international transactions requiring arm's length benchmarking under Section 92B of the Income-tax Act. Where the assessee's bank facility letter provides a reliable internal comparable uncontrolled price, that rate is preferred to unadjusted external bank guarantee rates because bank and corporate guarantees differ in creditworthiness, security and risk. The corporate guarantee commission is restricted to 0.60%, after credit for commission recovered from associated enterprises. Additional TDS/TCS credit requires verification of supporting factual material before relief may be granted.

Section 68 requires an assessee to establish each creditor's identity, creditworthiness and the genuineness of unsecured loan transactions. Financial particulars, banking records, creditor confirmations and repayment details can discharge that burden. Low reported income of lenders and the absence of formal loan agreements do not, by themselves, undermine creditworthiness where no contrary material disproves the evidence. Unsecured loan receipts remain satisfactorily explained when the Revenue does not rebut factual material supporting their genuineness.

Delayed electronic filing of Form No. 10-IE due to uncontroverted portal difficulties does not defeat an assessee's option for the concessional tax regime under section 115BAC where the option was unequivocally exercised. Filing the prescribed form with a revised return shortly after the extended due date constituted substantive compliance because the form was available with the Department and there was no complete non-compliance, abandonment, deliberate withholding, or misuse. The form should be considered and tax liability recomputed under the opted concessional regime.

Timely filing of the return is a mandatory condition for claiming Chapter VI-A deductions, including deduction for co-operative society income, where the return must be furnished by the due date. Processing of a belated return may disallow such deduction. A rectification application cannot restore the deduction because the disallowance resulting from late filing does not constitute a mistake apparent from the record. Consequently, the deduction remains unavailable and rejection of rectification is legally valid.

Rental income should not be increased through an estimated market rent drawn from an incomparable property in another city when no credible local evidence supports a higher rent and the disclosed rent exceeds standard rent. Salary paid to a family member is allowable where sustained business and banking functions establish genuine services, business results support the expenditure, and the recipient offers the salary to tax. Interest on unsecured loans may be commercially expedient despite a higher stated rate than secured borrowings, considering the effective cost of bank finance, flexibility and repayment terms. Unsupported rental estimates and unjustified salary or interest disallowances cannot be sustained where transactions are reasonable and genuine.

Section 167B does not apply to a public charitable society merely because its members' income shares are unspecified. The provision applies where members of an association of persons or body of individuals have indeterminate or unknown shares, whereas a public charitable body serves the public at large and its members have no entitlement to its income. Its income is therefore taxable at the normal rate applicable to an association of persons, rather than at the maximum marginal rate.

Section 87A rebate applied to tax computed on total income for the relevant period, with no express exclusion for tax on short-term capital gains chargeable at special rates under section 111A. The later restriction introduced by the Finance Act, 2025 operated prospectively and did not affect the relevant claim. Automated denial of the rebate could not displace the statutory entitlement. Rebate under section 87A was therefore available against tax payable on eligible short-term capital gains under section 111A.

Banking tax computation addresses arm's-length remuneration, provisions, securities valuation, income recognition and statutory deductions. Technical and IT-enabled services supplied to associated enterprises require value-based arm's-length remuneration; where reliable contemporaneous comparables are unavailable, a 10% cost mark-up is reasonable. Actuarially valued pension and employee obligations arising from past service are accrued liabilities, but leave encashment follows the actual-payment requirement. Banking securities may be consistently valued at cost or market value, whichever is lower, and interest on non-performing assets is taxable only on realisation under the real-income principle. Foreign-branch income remains taxable in India with treaty relief. Deductions for standard-asset provisions, bad debts and eligible business income depend on statutory conditions and verified computations.

Penalty proceedings under section 271D, where no assessment or related order exists during which they were initiated, fall under the six-month limb of section 275(1)(c). The relevant financial-year limb does not apply in that situation. The show-cause notice issued under section 274 read with section 271D constituted initiation of penalty action at the latest. As the penalty order was issued after expiry of six months from the end of that month, it was time-barred, quashed, and the sustained penalty was deleted.

Interest awarded under a foreign arbitral award becomes part of a judgment debt once the award is declared enforceable under section 49 of the Arbitration Act and treated as a court decree. The interest component then loses its separate character as interest. Because the amount does not arise from money borrowed or debt incurred, it falls outside the Income-tax Act definition of interest. The treaty provision governing interest income is therefore inapplicable, and the decretal amount representing arbitral interest is not taxable in India.

TNMM benchmarking for a limited-risk distributor of licensed content should assess comparability through functions, assets, risks, contractual terms and reliable financial data; product differences alone do not render software or hardware distributors unsuitable comparables. Rejection of the examined comparables solely because they were outside the film or entertainment industry lacked identified material functional or risk differences. An Other Method revenue split requires comparable uncontrolled transactions, reliable market evidence, or an objective economic basis for allocation. Assigned FAR weightages cannot quantify economic value merely by identifying functions and risks. TNMM was applied for arm's-length-price recomputation, deleting the consequential transfer-pricing adjustment.

Section 92CA(1) confines a Transfer Pricing Officer's reference to determining the arm's length price of a specified international transaction under section 92C. It does not extend to determining whether a permanent establishment exists under Article 5 of the India-Singapore tax treaty, or whether and how business profits are taxable and attributable under Article 7; those issues remain for the Assessing Officer. Where remand required the Assessing Officer to re-examine permanent establishment after cross-examination and consideration of relevant material, a reference without an identified international transaction exceeded transfer-pricing jurisdiction. An assessment based solely on such findings, without independent verification by the Assessing Officer, was unsustainable.