S. 119: Central Board of Direct Taxes-Circular-Co-operative society-Delay in filing return-Genuine hardship-Shortage of departmental auditors empanelled under Odisha Cooperative Societies Act-Genuine hardship-Principal Chief Commissioner should have considered the application under Section 119(2)(b) appropriately by allowing the assessee to avail the benefit of Section 80P.[S.80P, 119(2)(b),139(1), Odisha Cooperative Societies Act, 1962 (OCS Act), S 62, Art . 226]

S. 119 : Central Board of Direct Taxes-Circular-Return of income-Condonation of delay-For condonation of delay under Section 119(2)(b), mere residence abroad, senior citizen status, or ignorance of tax laws does not constitute sufficient cause or genuine hardship; rejection of the condonation application is justified. [S. 119(2)(b), 139, Art. 226]

S. 115BAA: Tax on income of certain domestic companies-Concessional tax regime-Failure to file Form No. 10-IC within the due date due to COVID and portal issues-First year of regulation-Genuine hardship arose from denial of benefit, resulting in substantial tax demand; delay in filing Form 10-IC was condoned. [S. 119, Form No 10-IC, R. 21AE]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Aggregation approach-Order of Tribunal affirmed. [S.260A]

S. 80IA: Industrial undertakings-Infrastructure development-Restricting the deduction by notionally brought forward losses and depreciation relating to the eligible undertaking pertaining to years prior to the initial assessment year, even though such losses and depreciation had already been set off against other business income in those earlier years, was unjustified-Section 80-IA(9) does not affect the computation of deductions available under other provisions falling under Heading “C” of Chapter VI-A . [S.80HHC, 80IA(5), 80IA(9), 80IB]

S. 69: Unexplained investments-Assessment-Violation of principles of natural justice-Reply of assessee explaining source of property purchase not considered while framing assessment-Assessment quashed and matter remanded for a fresh order after hearing assessee. [S. 143(3), 144B, Art. 226]

S. 69: Unexplained investments-Hawala-In cases of unaccounted sales/purchases, only the profit element embedded therein is taxable, not the entire turnover. [S.131(IA), 133A, 260A]

S. 68: Cash credits-Share capital-Identity, creditworthiness and banking trail for share capital established-Failure to use power under section 131-Order of the Tribunal deleting the addition was affirmed. [S.131, 260A]

S. 68: Cash credits-Share capital-Shell entities-PAN details, income tax return acknowledgements, and audited financial statements of subscriber companies who had confirmed transactions in response to notices issued under section 133(6)-Order of the Tribunal deleting the addition was affirmed.[S.131, 133(6), 260A]

S. 68: Cash credits-Discharged the initial burden-Order of High Court affirmed-SLP of revenue dismissed. [Art. 136]