“Section 113(3)”

Legislation is ordinarily presumed not to have retrospective operation, especially for taxing statutes unless explicitly stated or when intended to remove hardship for the assessee. The decision clarifies the principles for determining whether an amendment to a taxing statute applies prospectively or retrospectively, distinguishing between clarificatory and substantive amendments.

The expression "attributable to" is wider in scope and import than the expression "derived from" when interpreting provisions related to profits and gains from a business or industrial undertaking. The legislature's deliberate use of these distinct phrases indicates a nuanced intent regarding the directness of the nexus between income and the source.

An Income-tax Tribunal, operating anywhere in the country, must respect and follow the law laid down by any High Court, even if it is a non-jurisdictional High Court, as long as there is no contrary decision from another High Court on that specific legal point. The law declared by such a High Court is considered the final law of the land for the Tribunal.

The Assessing Officer is competent to accept or draw proper inferences from auditors' reports. When books of accounts are audited by chartered accountants and there is no material on record to show they are unreliable, no addition challenging deductions supported by those books is tenable.

Funds received by an entity acting as a nodal agency or agent of the government for implementing specific government schemes, or income generated from such funds (like lease premiums or interest), are not taxable in the hands of the agency if held on behalf of or remitted to the government.

The law declared by a High Court is binding on all subordinate authorities and tribunals within its territorial jurisdiction.

Section 153C of the Income Tax Act, 1961, cannot be invoked to assess an assessment year that falls beyond the six-year limitation period from the end of the financial year in which the satisfaction note was recorded by the Assessing Officer.

Beneficial statutes, especially procedural provisions, can be given retrospective effect if they are enacted for the benefit of the community as a whole, applying the doctrine of fairness, even without an explicit retrospective provision.