“Section 71(3)(a)”

Income deemed under sections 68, 69, 69A, 69B, or 69C of the Income-tax Act is a distinct category, separate from regular heads of income under Section 14, and losses from other heads, including business losses, cannot be set off against such deemed income.

The burden of proving an understatement of consideration or the receipt of 'on-money' lies solely with the Revenue, which must provide cogent evidence of actual receipt of higher consideration, beyond mere estimates or suspicion. Additions cannot be made based on assumptions like differences from circle rates without such evidence.

In search and seizure assessments under section 153A, if the assessment is unabated, the assessee cannot make fresh claims that were not made in the original return.

Investments made by a holding company in its subsidiary can be considered a business activity, allowing related business expenditures to be deducted and not disallowed.

Undisclosed income cannot be added based solely on seized documents or notings/jottings without corroborative or direct evidence that these materialized into transactions.

For an addition under Section 68, there must be a credit entry in the assessee's "books of accounts". A bank passbook is not considered the assessee's books of accounts for this purpose.

Expenditure incurred towards the purchase of shares is a capital expenditure and therefore, interest expenditure incurred on such purchases is not eligible for deduction under Section 36(1)(iii) of the Income Tax Act.

Expenditure incurred by a holding company for making investments in a subsidiary can be treated as business expenditure and is not disallowable, as such investment activity can itself constitute a business.