Charitable-registration applications rejected for absent or pending State public-trust registration, insufficient evidence of genuine activities, or curable filing defects require category-specific reconsideration. A subsequently obtained State-registration certificate must be verified for authenticity, validity and applicability, while a pending application should permit later production of the certificate. Genuineness requires examination of accounts, actual activities, supporting material and their nexus with stated objects, with disclosure of adverse material and a fair opportunity to respond. Curable defects in Form 10AB should be rectified where legally permissible. Consequential tax-exemption approval refusals require fresh consideration while retaining independent statutory conditions.

Rectification under Section 154 addresses apparent duplication where cash deposits are assessed both in a dissolved firm's assessment and in the successor proprietorship's assessment. Separate books showing that the deposits belonged to the successor proprietorship, together with disclosure and assessment of those deposits as undisclosed income in its scrutiny assessment, support treating the duplication as an error apparent from the record. The issue concerns correction of an existing factual error rather than fresh adjudication or reopening; the original assessment mode and absence of an appeal do not prevent rectification.

E-verification of an income-tax return relates back to its original filing date and does not make the return filed on the later verification date. Where the original filing occurred within the COVID-19 extension for statutory compliances, interest for delayed filing under section 234A is not leviable. A rectification under section 154 based on treating verification as the filing date is therefore illegal and unsustainable.

Unexplained-expenditure additions require evidence that the expenditure's source is unexplained, not merely vendor non-response to verification notices or later return-filing deficiencies. Expenditure recorded in unrejected books, paid through banking channels, and supported by invoices, vendor particulars, agreements, GST records and transaction data was treated as sufficiently evidenced unless the Revenue produced positive material discrediting it; the addition was therefore deleted. Rules on additional evidence do not require a remand report where no new document is admitted and the material comprises evidence already filed or explanations based on the assessment record.

Claimed exempt long-term capital gain on equity-share sales was not established as genuine merely through records of merger-based allotment, dematerialisation, and sale through a recognised intermediary. Investigation findings concerning the scrip, abnormal price movements, trading patterns, and absence of supporting financial fundamentals indicated conduct inconsistent with ordinary market behaviour. Failure to produce evidence of the company's intrinsic financial strength or rebut adverse findings, together with no new material against appellate findings, resulted in sustenance of the Section 68 addition.

Agricultural land's capital-asset status must be determined by measuring its distance from municipal boundaries in force on the transfer date; a certificate based on superseded boundaries is insufficient. The land's taxability consequently requires fresh determination on admissible evidence. Reassessment may proceed where property-sale information, non-filing of a return and an unsubstantiated exemption claim create a prima facie basis that income escaped assessment; prior approval is valid where recorded reasons receive due consideration. Indexed acquisition cost for inherited land and residential-investment exemption require evidence and verification of statutory conditions, with the taxpayer bearing the burden of proof.

Unrealised foreign-exchange gains arising on year-end reinstatement of foreign-currency ECB liabilities used to acquire capital assets in India must be recognised in taxable income under section 43AA. Section 43A's actual-cost adjustment mechanism applies only when its conditions, including acquisition of an asset from outside India, are met. Foreign-currency denomination or an overseas ECB source does not make assets acquired in India imported assets. Failure to satisfy section 43A does not remove the transaction from section 43AA.

Condonation of delay requires cogent material explaining the entire period of default. Ignorance of tax law, electronic communications, or the availability of an appellate remedy does not constitute sufficient cause without a satisfactory explanation for failing to challenge the revisionary order. Active participation with legal assistance in consequential proceedings also did not justify the delayed challenge to the foundational order. As the connected proceedings had already been restored for fresh adjudication, entertaining the belated challenge would unsettle operative directions. The delay was not condoned and the challenge was barred by limitation.

For assessment year 2016-17, the Finance Act 2020 amendment expanding "eligible assessee" to include non-residents did not apply. The non-resident assessee was therefore not subject to the extended assessment framework and the reassessment had to satisfy the ordinary limitation period. No reference to the Transfer Pricing Officer had been made, so the extended limitation available for transfer-pricing proceedings was also unavailable. The final reassessment order, issued after the applicable limitation period, was time-barred and quashed.

Pecuniary allocation under administrative instructions does not independently create or extinguish an Assessing Officer's statutory jurisdiction to issue a reassessment notice. Section 120 permits jurisdiction to be exercised under directions of competent authorities, including concurrent jurisdiction by more than one Assessing Officer. Section 127 permits transfer of a case without monetary-threshold restrictions, and a valid transfer order confers complete jurisdiction on the transferee officer. Where the assessment record does not establish whether a transfer order exists, the jurisdictional objection requires verification of that order and fresh determination.

Concessional taxation under section 115BAA requires cumulative satisfaction of prescribed conditions; filing Form 10-IC alone does not validate the option. A return claiming additional depreciation without reversal or adjustment, while computing tax under the normal regime, indicates non-compliance because that depreciation is barred under the concessional regime. An intimation under section 143(1) cannot disallow the depreciation by resolving the disputed legal and factual validity of the purported option, as such adjustments are confined to prima facie matters.

Independent exercise of quasi-judicial power by the Assessing Officer is essential to a regular scrutiny assessment under section 143(3). The statutory scheme does not authorise the Additional Commissioner's prior approval or consultation in making that assessment. Recorded consultation throughout the proceedings and approval before the order demonstrate absence of the Assessing Officer's independent application of mind and discretion, rendering the assessment void from inception and liable to be quashed.

Section 270A(6)(a) excludes income from under-reporting where a bona fide explanation is supported by full disclosure of material facts. Uploaded audited accounts and tax audit report, pre-notice tax payments, and acceptance of returned income supported cancellation of the penalty under Section 270A(3). Section 273B also protects a taxpayer from penalty for delayed furnishing of a tax audit report where reasonable cause is established. Pandemic-related disruption and director disputes delaying finalisation of accounts, followed by report upload and no prejudice to assessment, treated the delay as a technical breach and precluded penalty under Section 271B.

Section 10(26) salary exemption requires the claimant to prove that income accrued or arose from a source situated in the notified area or State, in addition to satisfying every other prescribed condition. An employer's letter recording a residential address in Shillong does not establish employment in Meghalaya or demonstrate that salary income arose from a qualifying source. Without an appointment letter or other supporting material proving the required source of income, the claimed exemption is unavailable.

Subscription fees paid for access to an online communication platform do not constitute royalty where customers receive only a limited, non-exclusive right to use the service and the provider retains ownership of the software, source code, copyright and intellectual-property rights. Customers must not obtain access to underlying processes or rights to modify, reproduce, exploit or own the software. Digital processes used by the provider to deliver communication, collaboration and file-sharing services are not made available to customers merely through platform access. Such receipts are business receipts and are not taxable in India without a permanent establishment.

Revisionary jurisdiction under Section 263 applies where an assessment is both erroneous and prejudicial to Revenue, including where mandatory inquiries or verification are omitted before allowing relief. Section 80AC makes timely filing of the return under Section 139(1) a condition for the relevant deduction, so allowing a Section 80P(2) claim without examining that condition may warrant revision. Examination of the deduction also falls within reassessment where the claim is directly connected with the explanation for deposits forming the basis of reopening, rather than being a wholly independent issue.

For fresh assessments under Section 153(3), the nine-month limitation period is reckoned from an operative order under Section 254, including a rectification order under Section 254(2) that directs de novo assessment. This approach avoids requiring completion of an assessment before later operative directions are issued. Where additions concern income from undisclosed sources, the status and supporting material relating to a connected prosecution remain relevant to determining taxable income. Failure to comply with directions to provide that material may permit the Assessing Officer to draw an adverse inference, while the quantum may require fresh consideration on the available evidence.

Protection against adverse action for failure to deduct tax at source from annual lease rent cannot be denied solely because a similarly situated assessee was not a party to earlier connected litigation. GNOIDA was treated as falling outside the expression "Government", requiring tax deduction from annual lease rent for the relevant assessment period; however, all similarly situated assessees were entitled to an opportunity of hearing. As the respondent had received no such hearing and the Authority's position was uniformly applicable, protection from adverse action remained available. Likely finalisation of GNOIDA's assessment also supported non-interference with the concurrent orders.

Penalty liability under Section 271(1)(c) for periods before 1 April 2016 requires application of Circular No. 25/2015 rather than automatic reliance on Explanation 4. The Circular treats the relevant explanation as prospective and makes penalty following an adjustment to computed income dependent on the nature of that adjustment. Where this framework was not considered, the penalty order and consequential demand notice were quashed, and the penalty liability was remitted for reconsideration under the Circular.

Concurrent factual findings on the attribution of impounded diaries, land-purchase material and cash transactions generally do not raise a substantial question of law in a further appeal. The statutory presumption relating to documents applies to the person from whose premises the material is found; absent independent evidence, recorded transactions cannot automatically be attributed to a firm. Additions for a partner's recorded cash credit may be limited after considering available sources and telescoping, while separate additions for unaccounted land consideration should not duplicate the same amount. Cash purchases neither recorded nor claimed as deductions cannot be disallowed as business expenditure.