“Section 64(4)”

An addition to income cannot be made solely on the basis of a statement recorded during a search under section 132(4) without independent corroborating evidence. Similarly, a penalty cannot be levied merely on the basis of assessment order findings, allowing the assessee to challenge the underlying facts in penalty proceedings.

An assessee's admission serves as an important piece of evidence but is not conclusive. The assessee can demonstrate that such an admission was incorrect or was made under a mistaken understanding.

A statement recorded during a search cannot be the sole basis for an addition to income, especially if made in violation of CBDT instructions and the provisions of section 132(4).

A question of an Assessing Authority's jurisdiction cannot be disputed after assessment proceedings are completed. Such disputes can only be decided by the Commissioner or the Board, not by an appellate authority under Section 246.

When undisclosed income from 'on money' in property transactions is assessed under Section 158BC, the addition should be a reasonable profit earned on the unaccounted turnover, with an 8% profit rate considered reasonable by the ITAT.

Income earned by a co-operative society on deposits made with banks is not considered attributable to its credit facilities business and therefore falls outside the scope of deduction under Section 80P.