Section 142A of the Income Tax Act

When the Assessing Officer conducts inquiries and accepts the assessee's explanation, the PCIT cannot invoke revisional powers under Section 263 solely due to a difference of opinion with the conclusion drawn by the AO.

Reassessment proceedings under section 147/148 are invalid if based on a mere change of opinion by the Assessing Officer after a regular assessment under section 143(3). Initiating reassessment requires fresh tangible material and proper sanction under section 151.

The Assessing Officer cannot make additions to income solely based on a Valuation Officer's report under Section 55A or 142(2), particularly for unexplained investments or expenditure under Section 69B, as the AO is the primary fact-finding authority (this was the position pre-Section 142A).

A taxing statute must be strictly construed: the subject is not to be taxed unless the charging provision clearly and explicitly imposes the obligation, without room for intendment or implication. There is no equity about a tax, and nothing is to be read into or implied within the language used.

Seized material from a search under Section 132 can be used to presume similar transactions and extrapolate findings of unaccounted expenditure across the six assessment years covered by Section 153A. This allows for estimation and projection based on limited seized evidence.

A retracted statement recorded under Section 132(4) of the Income-tax Act, particularly when made under stress during a search, has no evidentiary value and cannot be the sole basis for an income addition without independent corroborative evidence.

A direction for special audit under Section 142(2A), issued near the expiry of the limitation period primarily to gain an extension of time or with instructions beyond the section's scope, is illegal, rendering the subsequent assessment time-barred.

Share premium and share application money cannot be added as unexplained cash credits under Section 68 if the genuineness of the transaction and the creditworthiness and identity of the investors are established. The onus is on the revenue authorities to prove that the apparent nature of the receipt is not real.

When estimating construction costs or expenditure for assessment, local PWD rates must be preferred over CPWD rates, as CPWD rates are generally higher.