“Section 130(3)”

Penalty under Section 271(1)(c) is not automatically imposed upon an assessee's failure to contest a quantum addition or if two views are possible; the Assessing Officer must prove the charge of concealment or inaccurate particulars. Furthermore, an Assessing Officer can disallow a claim during assessment if it is patently false on examination of facts.

For computing presumptive income under Section 44BB, gross receipts do not include service tax reimbursements received from a client (like ONGC) if such amounts are not payments for services or plant/machinery directly used in the prospecting, extraction, or production of mineral oils.

The sanctioning authority must apply its mind to the reasons recorded by the Assessing Officer before granting approval for reassessment or other proceedings, and cannot grant such approval in a mechanical manner by merely rubber-stamping "Yes".

Interest income, such as on income-tax refunds or fixed deposits, derived by a foreign entity with a Permanent Establishment (PE) in India is taxable under DTAA if the debt-claim is effectively connected or attributable to the PE. For DTAA purposes, the terms 'attributable' and 'effectively connected' are considered to have the same meaning.

Revisionary power under Section 263 cannot be exercised arbitrarily; it has limits and does not apply to every inadequacy in the Assessing Officer's inquiry or verification.

Additions to income cannot be made based solely on statements or confessions recorded at the time of a search, without corroborating evidence. Such confessions lack evidentiary value if not supported by other proof.

An excess of income over expenditure does not, in itself, mean that an educational institution exists for profit, rather than solely for educational purposes. The primary purpose test is key.

Revision under section 263 of the Income-tax Act is not valid if all particulars were furnished to the Assessing Officer and the officer applied their mind to the issue.