“Section 139(6)”

Reassessment proceedings under Section 147 are valid even after a scrutiny assessment under Section 143(3), provided the Assessing Officer forms a reason to believe, based on definite, specific, and reliable information, that income escaped assessment due to the assessee's failure to fully and truly disclose material facts.

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

An increase in a company's subscribed share capital cannot be treated as the company's undisclosed income under section 68, even if the subscribers to the capital are found not to be genuine. The amount of share capital cannot be regarded as undisclosed income of the company itself.

Taxing statutes must be interpreted strictly, assuming that the law-making authority does not commit a mistake or make an omission. There is no room for purposive interpretation under direct tax laws.

Orders that are inordinately delayed are liable to be recalled and heard afresh, and the Appellate Tribunal President should frame guidelines for timely disposal of appeals.

The Kerala High Court held that charitable institutions claiming exemption under Section 11 are not entitled to claim depreciation on assets used for charitable purposes, taking a view contrary to most other High Courts.

In matters concerning condonation of delay, courts must adopt an overall view in the larger interest of justice, prioritizing substantial justice over mere technicalities. Adjudication on merits should not be denied unless the delay in filing an appeal is found to be deliberate, intentional, careless, negligent, or the litigant's conduct clearly lacks bona fides.

The Commissioner of Income Tax (Appeals) is duty-bound to dispose of appeals on their merits, even when proceeding ex-parte. This requires framing points for determination, providing detailed reasoning for the decision, and affording the assessee a reasonable opportunity of being heard, as mandated by Section 250(6).