“Section 172(3)”

Interest income earned on deposits, particularly before the commencement of business operations or as a requirement for business licensing, is taxable as "income from other sources" under Section 56, and cannot be treated as business income or set off against interest on borrowed funds.

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

An expenditure is classified as either capital or revenue; the 'enduring benefit' test is a key criterion for this distinction, and income tax law does not generally recognize deferred revenue expenditure unless specifically provided.

When an assessee fails to discharge the onus of proving the genuineness of purchases and their source, the entire value of such bogus purchases is added as unexplained expenditure under Section 69C, rejecting any estimation of a profit rate.

An Assessing Officer acts in a quasi-judicial capacity during assessment and must follow elementary rules of judicial procedure, conducting the case personally without interference from superiors.

Income received by a trust from sources like extra fees can be taxed at the maximum marginal rate, while other income remains eligible for exemption under Section 11 of the Income Tax Act.

Payments to a non-resident agent for services rendered outside India, where the agent has no permanent establishment (PE) or business connection in India, are not chargeable to tax in India. Consequently, there is no obligation to deduct tax at source under Section 195, and no disallowance under Section 40(a)(i) can be made.

The ITAT Jaipur Bench, in the context of search and seizure action under section 132(1), refers to this case alongside other decisions, indicating its relevance in matters arising from search and seizure.