“Section 125(1)(a)”

The levy of penalty under Section 271(1)(c) requires material evidence that the assessed amount does not represent the assessee's income and proof of conscious concealment or furnishing inaccurate particulars. A penalty cannot be sustained merely because income is assessed on an estimation basis without positive evidence of concealment.

When determining income from house property under Section 23, the Annual Letable Value (ALV) can be estimated by deeming 7% of the property's value as notional rent, particularly when actual rent or other clear basis for ALV is absent.

The assessee bears the burden of proving the genuineness of transactions, including the identity, creditworthiness, and genuineness of parties involved in purchases, especially when the parties have migrated or cannot be located.

An order imposing penalty under section 271(1)(c) cannot be sustained if the Assessing Officer does not make a specific finding that the assessee furnished inaccurate particulars of income or concealed income. The penalty is not leviable in cases of mere disallowance or a bonafide claim.

A penalty order is liable to be quashed if it is based on a finding that lacks legal basis. The penalty order cannot be sustained in the eyes of law if the same is based on flawed reasoning.

An assessee is entitled to interest under section 244A on self-assessment tax paid, with interest computed from the date of payment until the refund is granted.

Foreign taxes not eligible for double taxation relief may be allowed as a deduction under Section 37(1) of the Income Tax Act, 1961, if the tax credit has not been granted for those taxes.

The actual cost of an asset for depreciation purposes is its original cost to the assessee, reduced by any portion met by others.