S. 68 : Cash credits-Unexplained investment-Natural justice-Show cause issued under s. 68-Final order passed under s. 69A without opportunity-Order set aside [S. 69, 144B, 147, Art. 226]

S. 40(a)(i): Amounts not deductible-Deduction at source-Non-resident-Agency commission-Tribunal order deleting disallowance affirmed-No substantial question of law. [S. 195, 260A]

S. 28(i) : Business income-Income from house property-Rental income from properties-Income assessable as business income and not as income from house property-Order of Tribunal was set aside [S. 22, 260A]

S. 12AA : Procedure for registration-Mere registration under S. 12AA automatically does not entitle a charitable trust to claim exemption under ss. 10 and 11-AO has to verify genuineness of claim-Reference to Larger Bench declined-SLP of Revenue dismissed [S. 10, 11, Art. 136]

S. 12A : Registration-Non-disposal within six months-No deemed registration-Tribunal order set aside-Appeal of revenue was allowed. [S. 12AA(2), 260A, Art. 141, 142]

S. 10(26AAA) : Income of Sikkimese-Individual-Clarification provided as per Press Release dated 4th April 2023-Term “Sikkimese” defined in Finance Act, 2023 applies only for Income-tax purposes-Constitutional validity of Expln. (v) upheld-Writ dismissed. [Art. 371F(k)]

S. 12A : Registration –Trust or institution- Delay in filing audit report – Condonation of delay in filing Form 10B – Justice oriented approach should prevail over a pedantic one – Delay of 27 days condoned- Order of Commissioner ( E ) was set aside . [S.11, 12 , 119, Form No . 10B, Art. 226 ]

Direct Tax Vivad Se Vishwas Act, 2020 (DTVSV Act)
S. 4 :Declaration-Declarant-Appellant-Tax arrear-Disputed tax-Settling of one issue-Disallowance of loss-Revenue can not compel assessee to settle disputes which were not subject matter of declaration made by assessee-Competetnt Authority is directed to issue the certificate. [S.2(1)(c), 2(1)(o), 2(1)(j), 3, 5(1), Form No 3, ITACT, S. 68, Art.226]

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015

S. 51:Pushishment for wilful attempt to evade tax-Return of income-Prosecution under section 51 cannot be dependent on completion of assessment, as offence, if proved, stands completed as soon as conditions as required under section 51(3) are fulfilled, irrespective of return of income-Writ petition to quash the proceeding is dismissed. On SLP the Court held that the assessee was to be permitted to raise all contentions legal as well as factual available to him before concerned authority under provisions of Black Money Act, 2015 and relevant contentions were to be considered on their own merits without being influenced by impugned order. SLP filed against order of High Court was to be disposed of SLP [S.2(12), 10(1), 48, 51(3), ITACT, 1961, S. 6(6), 131(IA),132, Art. 136,]

S. 281B : Provisional attachment-Seizure of cash from a car-Reassessment proceedings-Attachment of bank account-Money in a bank is a property liable for provisional attachment-Single judge held that bank account was not a property hence canot be subjected to provisional attachment-On appeal division Bench up held that provisional attachment-Order of single judge was set aside. [S. 132B, 226(4), Bharathiya Nagarik Suraksha Samhitha, 2023, S. 497, Code of Civil Procedure, 1908 (CPC) S 60(1), GST Act, 2017, Code of Criminal Procedure, 1973, S.451, Art. 226]