“Section 231(1)(a)”

The term 'record' under Section 263(1) of the Income Tax Act includes all material available to the Commissioner at the time of his examination, not merely the records that were available to the Assessing Officer when the original assessment order was passed.

The actual cost of an asset is distinct from the cost of borrowing money for its purchase. Foreign exchange fluctuations on loan repayment do not alter the asset's actual cost and are not covered by Section 43A.

The Commissioner's revisional powers under Section 263, as clarified by Explanation (c) of Section 263(1) (retrospectively inserted by the Finance Act, 1989), extend to and are deemed always to have extended to matters that were not considered and decided in an appeal. This means the CIT can revise an order even if it was appealed, provided the specific issue under revision was not part of the appeal proceedings.

This case establishes principles for distinguishing operating leases from finance leases and determining if leased equipment constitutes a Permanent Establishment (PE). It also clarifies that reassessment proceedings initiated on borrowed satisfaction without independent application of mind are invalid.

Expenditures are revenue in nature and deserve to be allowed as deductions if they are for commercial expediency.

Electronic records downloaded from electronic items cannot be relied upon at face value and require corroboration with other evidence for income-tax additions.

Reassessment proceedings must be based on fresh tangible material and not merely a reappraisal of existing evidence or a change of opinion by the Assessing Officer. There must be some information that leads the officer to believe income has escaped assessment.