“Section 144(7)”

Penalty under section 271(1)(c) for furnishing inaccurate particulars cannot be imposed for a mere disallowance, bona fide mistake, or inadvertent error, especially when relevant facts are disclosed in the tax audit report. The levy of penalty requires proof of intent to conceal income or furnish false particulars.

The law of limitation must be applied with all its rigour, and courts cannot extend the period of limitation on mere equitable considerations or for casual explanations without sufficient cause. Parties must demonstrate diligence and a bona fide reason for the delay.

The law of limitation applies to all, including the government. Condonation of delay in filing appeals requires a party to demonstrate sufficient, bona fide, and reasonable cause, as courts should not condone delays mechanically or for routine explanations, gross negligence, or inaction.

Income is chargeable to tax in India only to the extent it is reasonably attributable to operations carried out in India, especially when the amounts paid to associated enterprises are at arm's length.

A presumption under Section 114(e) of the Indian Evidence Act can only be drawn from established facts through probable and logical reasoning, not from other presumptions. Consolidated approval for multiple assessment years by an approving authority renders the requirement of individual approval for each year under Section 153D nugatory.