Reassessment requires information that objectively suggests income has escaped assessment; a PAN-based attribution mismatch does not meet that threshold where the transferred business's income was disclosed and taxed by the demerged entity. Section 148A requires application of mind to supporting material and connected records, rather than reassessment merely for verification or a roving inquiry. The extended reassessment period applies only where books, documents, or evidence reveal previously undisclosed income meeting the statutory threshold. Recorded and taxed transactions requiring correlation are not undisclosed income, so they cannot support extended limitation after the ordinary period has expired.

Reassessment under Sections 147, 148 and 148A requires information indicating income has escaped assessment, with a live link and rational nexus to that conclusion. A Section 148A show-cause notice and the subsequent determination must consider the material on record and the assessee's reply. A verification report produced under Section 131(1A) cannot support adverse inferences extending beyond its limited inquiry without independent verification. Where audited accounts, bank records, utilisation details and vouchers are not addressed, and scrutiny is sought merely for further examination, the process is a roving inquiry. The jurisdictional threshold fails, making the determination and reassessment notice unsustainable.

Section 170A(2)(b) requires a modified return filed during pending assessment proceedings following a business reorganisation to be considered within those existing proceedings. A draft assessment order does not end the assessment because the DRP process continues until a final appealable order is passed. Section 170A(3) does not create a separate assessment cycle or allow general assessment provisions to override this specific mechanism. Where the modified return has been considered in the pending assessment and a final order issued, a fresh scrutiny notice, consequential transfer-pricing reference, and parallel proceedings lack statutory basis and suffer from a jurisdictional defect.

Spare-replacement activities conducted without ownership of the parts, control over resale prices, or customer selection are characterised as service-provider functions for transfer-pricing purposes. The functional, assets and risks profile supports benchmarking under the Transactional Net Margin Method where the entity merely holds and delivers replacement parts to customers of its associated enterprise under that enterprise's directions. The Resale Price Method is not appropriate for such custodial service activity, as the entity does not undertake trading functions or assume the corresponding risks.

Section 260-A permits an appeal only where a substantial question of law arises. For transfer-pricing determination of the arm's length price of research and development services, functional comparability was undisputed. Exclusion of Neeman Medical International (Asia) Limited rested only on an assertion of consistent losses, but the financial material did not establish a consistently loss-making position. Its inclusion as a functionally comparable entity therefore did not raise a substantial question of law.

Penalty for under-reporting or misreporting is not attracted where a CSR-related deduction claim is supported by binding precedent and the underlying addition is deleted. An education cess deduction claimed under then-binding jurisdictional precedent, but relinquished after a retrospective amendment reversed that position, does not warrant penalty. Under the APA framework, timely filing of a modified return requires total income to conform to the agreement; a royalty adjustment thereby resolved, with complete disclosure, does not constitute under-reporting, misrepresentation or suppression. These principles exclude penalty where claims were legally supported when made and relevant transactions were fully disclosed.

Section 10(23FB) exemption applies where a trust is registered as a venture capital fund; separately maintained contributory schemes need not obtain individual registration. Submission of a scheme-specific private placement memorandum does not make the scheme an independently registrable fund. For the associated-company restriction, the shareholding test applies to trustees', settlors', sponsors' or directors' personal holdings, not shares held solely by trustees in a fiduciary capacity for the fund. This treatment preserves the fund's eligibility for the statutory exemption.

In a concluded assessment, additions under Section 153A require incriminating material found during search. Board resolutions, legal notes, valuation reports and related records concerning a firm's conversion, constitution and prior transactions do not meet that requirement where they disclose no undisclosed income; additions founded on them lack legal basis. Tax-neutral succession under Section 47(xiii) remains available where the business assets and liabilities existing immediately before succession vest unchanged in the company and partners receive only shares reflecting their pre-succession interests. Asset sales and changes in capital-sharing ratios before succession do not, by themselves, breach those conditions or justify denial of the Section 80-IA deduction.

Uncorroborated loose sheets containing scribbled figures cannot, by themselves, support an addition for undisclosed consideration in a property purchase. In a search assessment, such sheets are not books of account and require corroborative incriminating material. Without evidence of cash payment or of the availability and deployment of funds beyond the consideration recorded in the registered sale deed, the addition is unsustainable.

Section 148A(b) required that the assessee receive 30 days to respond before reassessment action. Curtailing that period to 15 days despite a timely extension request, when sufficient time remained for consideration, prejudiced the assessee's right to be heard. A reply uploaded before the Section 148A(d) order but not considered violated principles of natural justice. The Section 148A(d) order and consequential Section 148 notice were set aside, requiring a fresh decision after considering the reply in accordance with law.

Reassessment after a completed scrutiny assessment cannot revisit the existence of a permanent establishment where the issue was specifically examined, the taxpayer furnished detailed replies, and reopening relies on the same material. The absence of an express finding in the assessment order does not permit correction of an Assessing Officer's omission; such reopening constitutes a change of opinion and undermines assessment finality. Beyond four years, reassessment requires income escapement caused by failure to make full and true disclosure. Where subscription receipts and the Indian agent's role were disclosed during scrutiny, that condition is absent, and a notice issued after the applicable limitation period is time-barred.

Section 69 applies where investments are unrecorded in the books and the assessee fails to satisfactorily explain their nature and source; Section 115BBE governs the tax treatment of income assessed under that provision. Investments, loans and advances disclosed in the books and substantiated by bank records and audited financial statements, including brought-forward balances, do not support additions as unexplained investments. The Tribunal's factual assessment of those materials disclosed neither perversity nor illegality, so deletion of the additions did not give rise to a substantial question of law.

Recall of the writ proceeding was allowed. The revived petition was then closed, but the closure did not prevent institution of fresh proceedings on the same cause of action. Fresh proceedings may be instituted on that cause of action and may include a challenge to Section 147A. Existing protection was continued for 90 days.

Reassessment proceedings may be challenged afresh where a statutory amendment alters the basis for assessing-officer jurisdiction. Following the Supreme Court's remand approach, the earlier judgment was recalled and the writ petition was closed with liberty to initiate fresh proceedings on the same cause of action, including a challenge to Section 147A and consequential reliefs. Interim protection was continued for 90 days, but would cease if fresh proceedings were not commenced within that period.

Reassessment challenges concerning the validity of orders under section 148A(d) and notices under section 148, including alleged defects in sanction or approval under section 151, were remitted for fresh consideration after the Supreme Court set aside earlier High Court judgments on a limited ground arising from a subsequent statutory amendment. The earlier judgment was recalled, the writ petition was closed with liberty to file a fresh petition on the same cause of action, including a challenge to section 147A, and existing interim protection continued for 90 days.

Condonation of delayed returns seeking the Section 80P deduction is governed by the specific CBDT scheme for cooperative societies, rather than general guidance concerning delayed refund or loss claims. The specific scheme requires consideration of circumstances beyond the taxpayer's control, including delays in statutory audit, and whether genuine hardship arose. Delayed receipt of an audit report through the State Audit Department during COVID-19 restrictions, followed by an explained short filing delay, supports a liberal rather than hypertechnical approach to condonation. Once delay is condoned, the delayed return may be considered for the Section 80P deduction in accordance with law.

Employee Stock Option Scheme expenditure may be debited to the profit and loss account as allowable revenue expenditure. For Financial Year 2017-18, a share valuation report issued by a Chartered Accountant cannot be rejected under a later requirement for Merchant Banker certification, because that requirement applied only from the subsequent financial year. Consequently, an addition under Section 56(2)(viib) based solely on the absence of Merchant Banker certification is unsustainable for the relevant year.

Input tax credit on GST paid for land-survey charges incurred to acquire land surrendered for afforestation is unavailable. Survey services for alternate land surrendered to the Forest Department lack the required nexus with business because that land neither remained with the taxpayer nor generated taxable outward supplies. Survey services relating to golf-course land are preliminary services directly connected with construction or development of immovable property on own account and fall within blocked credit for such construction. Services relating to alternate land surrendered and written off are also treated as blocked credit for goods or services written off. Land transactions are outside the scope of supply.

Specialised laboratory-based sex sorting of bovine semen is classified under SAC 998349 as other technical and scientific services, rather than under SAC 9986 for support services to agriculture, forestry, fishing and animal husbandry. The intermediate-production-process coverage in Heading 9986 applies only to job work related to rearing life forms; laboratory separation of X- and Y-bearing sperm does not directly involve livestock rearing or animal-husbandry activities. Services under Heading 9983 are taxable at 18% GST and receive no exemption. The classification therefore treats semen sorting as a residuary technical and scientific service.

Weekly-market fee collection rights leased by a Town Panchayat to a tender contractor remain activities connected with the Panchayat function of markets and fairs where the Panchayat prescribes fees, issues receipts in its name, and retains control. Outsourcing collection for operational convenience does not convert that public-authority function into an independent commercial activity. As an activity undertaken by a local authority in relation to a function entrusted to Panchayats under Article 243G, the arrangement is treated as neither a supply of goods nor a supply of services under the GST framework and is therefore outside GST.