“Section 146(3)”

Reasons for reopening an assessment must be specific and not vague, scanty, or based on borrowed satisfaction. The Assessing Officer must quantify the escaped income.

Depreciation claimed by a charitable trust on its assets is an allowable application of income for computing exemption under Section 11, and this does not constitute a double deduction.

Sections 4 and 5 of the Income Tax Act, which define total income and chargeability, are subject to Section 90, meaning that Double Taxation Avoidance Agreements (DTAAs) override the Act's provisions in case of a conflict.

Reassessment proceedings under section 147 cannot be initiated by the Assessing Officer based on borrowed satisfaction, vague information from the Investigation Wing, or incorrect jurisdictional facts without independent application of mind. Reopening beyond four years from the end of the relevant assessment year, especially where an original assessment was completed under section 143(3), requires specific conditions relating to the assessee's failure to disclose material facts.

The phrase 'sufficient cause for not making the application within the period of limitation' is to be understood and applied liberally. The burden of proving 'sufficient cause' rests on the appellant.

A document seized during a search operation indicating a higher consideration for a property purchase is relevant evidence for making an addition to income, even if the assessee later contests its validity.

An order passed under section 263 is invalid and can be declared so if it does not contain a Document Identification Number (DIN).

Interest paid under section 201(1A) for delayed payment of TDS is compensatory in nature and allowable as a business expenditure. TDS component paid on expenses incurred is not in the nature of income-tax of the assessee and therefore, no disallowance can be made under section 40(a)(ii).