S. 40(a)(ia): Amounts not deductible-Deduction at source-Short deduction of tax at source-Merely a short deduction of TDS by assessee under section 194C, and persons to whom payments were made by assessee had paid taxes on such payments, Assessing Officer could not have invoked provisions of section 40(a)(ia) and disallowed expenses claimed by assessee-Order of Tribunal affirmed. [S. 194C; Second proviso, 194I, 260A]

S. 37(1): Business expenditure-Infrastructure fee-Advertising receipts-Tribunal was justified in restricting deduction to 5 per cent of actual receipts in accordance with the agreement and not on the gross advertising bill-Order of Tribunal affirmed. [S.145, 260A]

S. 37(1): Business expenditure-Broken period interest-Securities held as stock-in-trade-Deduction allowable.[S.145, 260A]

S. 37(1): Business expenditure-Personal element-Disallowance-Pure finding of fact-Commission payment-Services not established-Finding of fact-No substantial question of law.[S.260A]

S. 37(1) : Business expenditure-Client assistant charges-Three-in-one account scheme-Expenditure incurred for business allowable-Provision for loss-Contingent liability-Conservative principle-Deduction allowable [S. 145, 260A]

S. 36(1)(vii) : Bad debt-Advances-Business loss-Write-off of unrecovered advances-Genuineness not disputed-Deduction allowable. [S,28(i), 260A]

S.14A: Disallowance of expenditure-Exempt income-Interest-free funds-Non-interest-bearing funds were more than the investment made in tax-free securities; it would be presumed that the investment made by the assessee would be from its interest-free funds and, thus, no disallowance under section 14A could be made-Order of Tribunal affirmed. [S.260A, Rule 8D]

S. 10A: Free trade zone-STP Unit-New infrastructure, plant and machinery, software and separately recruited workforce-Undertaking not formed by splitting up or reconstruction of existing business-Deduction allowable-Order of Tribunal affirmed. [S. 10A(2), 260A]

Direct Tax Vivad Se Viswas Act, 2024.
S 91 : Filing of declaration and particulars to be furnished-Prior tax position revived when assessee does not comply with provisions / requirements of DTVSV Act 2020 and hence eligible under DTVSV Act 2024.[DTVSV Act, 2020, S. 4(6), 5(1)Art. 226]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-When the subject matter of the penalty, which was the very basis on which criminal proceedings had been launched, was set aside, criminal proceedings could not be allowed to continue.[S.271(1)(c), 277]