Reassessment notices and a consequential assessment issued in the name of a transferor company after its amalgamation were unsustainable because the entity had ceased to exist from the appointed date. The appointed date preceded issuance of notices for reassessment and scrutiny assessment, and the tax authorities had been informed of the amalgamation. Proceedings against the erstwhile amalgamated entity were therefore invalid, resulting in quashing of the reassessment notices and consequential assessment.

Foreign tax credit under Section 90 cannot be denied solely because Form No. 67 was filed after the prescribed time where the return was filed within the extended due date and substantive eligibility is otherwise undisputed. Rule 128 is a procedural machinery provision governing the method of claiming credit and cannot override the substantive entitlement to treaty relief when prescribed conditions are fulfilled. Amended Rule 128(9) permits Form No. 67 to be furnished by the end of the relevant assessment year where the return is timely filed. The credit remains subject to necessary verification.

Penalty for an alleged contravention of the cash-receipt restrictions cannot survive where the underlying reassessment has been annulled and the corresponding addition deleted. The penalty was founded on the cash-transaction allegation in the quantum assessment and was consequential to the validity of that assessment. Once the assessment ceased to exist, there was no independent basis for the penalty. The penalty imposed under section 271D was therefore unsustainable and quashed.

Cash deposits claimed as agricultural sale proceeds require satisfactory substantiation of their source. Accepted land records and crop reports establish agricultural activity, while deposits made in tranches matching harvesting seasons and withdrawals for agricultural purposes corroborate the explanation. For a small agriculturist, the absence of crop-sale bills alone does not justify treating deposits as unexplained where no alternative source is identified. On these facts, the deposits were treated as fully explained agricultural proceeds and the unexplained-money addition was deleted.

Cash deposited during demonetisation by a small trading business was explained by accepted presumptive turnover and income. Where income is computed under the presumptive taxation scheme and the taxpayer is not legally required to maintain or audit books, internally prepared records cannot alone negate the explanation. The deposit therefore could not be treated as unexplained money or taxed at the special rate.

Reassessment involving the sale of one residential property and investment in another requires fresh examination of the taxpayer's contentions after an adequate opportunity of hearing. The Assessing Officer must decide the issues afresh in accordance with law. The merits of the additions and the capital-gains claim remain unadjudicated, requiring fresh adjudication rather than a substantive determination of the tax claims.

Income-tax additions for alleged penny-stock transactions require substantive and corroborative evidence linking the taxpayer to undisclosed income. Recorded share purchases and sales showing a loss cannot be displaced merely by investigation-wing information where no material rebuts the transactions. Likewise, an estimated profit from alleged share trading cannot rest on system information, presumptions, or a percentage-based computation when the activity is specifically denied and remains unproved. Both additions were deleted for lack of substantive corroborative evidence.

Section 119(2)(b) provides an additional administrative remedy and does not displace the statutory appellate remedy to examine substantive entitlement to exemption for deemed application of income under section 11. Although Form No. 9A is prescribed, its filing mode and timing are procedural, and substantial compliance may suffice. Where electronic filing had been newly introduced, the form was filed during assessment proceedings, the delay was about three months, and no deliberate or mala fide conduct was established, sufficient cause existed for condonation. The delayed form may be treated as valid, subject to verification of the remaining statutory conditions for the claim.

Section 69 does not apply where an immovable-property investment is recorded in a partnership firm's regular books and funded through identifiable partners' capital accounts. In the absence of defects in or rejection of the books, the firm's recorded investment cannot be treated as unexplained merely because concerns arise about individual partners' financial capacity or sources of funds. Those concerns require examination in the respective partners' assessments. Accordingly, an addition for unexplained investment is unsustainable and must be deleted.

Principles of natural justice require appellate adjudication under the Income-tax Act to afford an adequate opportunity of hearing. Where hearing notices go unanswered, non-compliance alone does not exclude circumstances warranting a further opportunity to submit evidence and information on disputed additions and consequential penalties. Ex parte appellate orders sustaining such additions and penalties were set aside, and the matters remitted for fresh adjudication after an adequate hearing opportunity.

Unrealised mark-to-market gains on specified excluded forward exchange contracts are recognised for tax purposes only on settlement under Section 43AA and Income Computation and Disclosure Standard VI. Paragraph 8(5) requires settlement-based recognition of exchange differences for those contracts; financial-reporting recognition under Accounting Standard-11 does not control taxable-income computation. Accordingly, unrealised gains recorded in the books before settlement are not taxable in the relevant years, and additions based on such pre-settlement recognition are unsustainable.

TNMM benchmarking using an OP/OC profit level indicator requires reliable segmental profitability, including a demonstrated allocation of common operating expenses. A BPO segment with unallocated entity-level expenses may understate costs and overstate margins and should be excluded as unreliable. A separate software-development business does not disqualify an entity where distinct ITeS segment results are available and the retained segments are functionally comparable. Information collected from a proposed comparable supports benchmarking only if the relevant segmental financial data reliably reflects profitability.

Cash deposits were accepted as explained only where cash-flow entries were supported by corresponding prior withdrawals. An opening cash balance lacked evidence of the preceding year's closing balance, and cheque payments recorded as withdrawals could not establish cash availability for subsequent deposits. Deposits matched by withdrawals made immediately beforehand were treated as supported. Interim deposits and agricultural expenditure remained unexplained, resulting in the addition being restricted to the unexplained components.

Cash deposits during the demonetisation period cannot be treated as unexplained money merely because of the timing of deposit when accepted business turnover in the same accounts provides an apparent source. Section 69A applies only after its statutory conditions are established through material showing an independent, non-business source or an abnormality in the business. Where receipts are accepted as turnover, assessment should ordinarily be limited to the profit element rather than a separate addition of gross receipts. A best-judgment assessment must be fair, material-based, and free from conjecture.

Interest on compulsorily convertible debentures remains eligible for allowance while the instruments subsist as debt and have not been converted or redeemed. Ind AS classification of a compound financial instrument partly as equity is a disclosure treatment that does not, by itself, recharacterise outstanding CCDs for transfer-pricing purposes; actual conversion or redemption requires verification. Likewise, no separate notional-interest adjustment arises on overdue associated-enterprise receivables where interest is uniformly not charged on comparable delayed receivables from unrelated customers. The same commercial policy establishes comparable conduct and renders the receivables adjustment unsustainable.

Section 92C(3) permits rejection of a transfer pricing analysis only where the data used to determine the arm's length price is unreliable or incorrect. Modification of comparability filters alone does not justify discarding a study when its functional analysis, tested party, databases, search methodology and contractual terms are undisputed. The arm's length price for software development services requires re-examination using the taxpayer's database, modified filters and accept-reject matrix. Delayed associated-enterprise receivables can require a separate interest adjustment unless aggregated in transactional net margin method margins after working-capital adjustment; associated-enterprise payables cannot automatically be set off against receivables.

Transfer-pricing method selection under Rule 10B depends on the tested party's functional profile. Product-replacement services involving custody and delivery of spares, nil-value supplies, a fixed cost markup, no control over customers or resale prices, and no material inventory or product risks indicate a captive service-provider profile rather than a trading function. TNMM is therefore appropriate for benchmarking that segment, while RPM is unsuitable because the segment does not undertake independent resale functions or bear trader-level risks. The functional analysis supports acceptance of TNMM for the product-replacement segment.

Substantial questions of law in an appeal confined to a miscellaneous-application order must arise from determinations made in that order. The finding that an Indian subsidiary was not a dependent agent permanent establishment remained unaltered because the software-sale transaction was accepted as a purchase-and-sale transaction and subjected to arm's-length-price determination. Challenges directed at that earlier, unmodified finding do not arise from an order modifying remand directions. The earlier order may be challenged separately in accordance with law.

Reassessment proceedings concerning domain-registration receipts were stayed pending further hearing. Prior determinations on the characterisation of those receipts, the absence of a permanent establishment, and earlier scrutiny assessments were relevant to the challenge. The reassessment action was prima facie considered inconsistent with objectivity, certainty and finality in tax adjudication. The High Court issued notice and stayed the reassessment proceedings pending the next hearing.

Section 152(3) preserves the pre-Finance (No. 2) Act, 2024 reassessment framework under Sections 147 to 151 where a third-party search was initiated between 1 April 2021 and 1 September 2024. For such searches, the pre-amendment Explanation 2(iv) to Section 148 continues to apply despite its later omission. The Assessing Officer is consequently deemed to possess information suggesting income escaping assessment and may issue a reassessment notice directly under Section 148 without first issuing a notice under Section 148A(b).