S. 271(1)(c) : Penalty—Concealment-No order of imposing or enhancing or reducing or cancelling penalty or dropping proceedings for imposition of penalty shall be passed unless assessee is heard or has been given a reasonable opportunity of being heard and after expiry of six months from end of year of which order of appellate authority has been received by Commissioner. [S. 275 (IA)]

S. 234E : Fee-Default in furnishing the statements- No enabling provision to impose fees for late filing of return or statement of TDS prior to 1st June, 2015–AO had no jurisdiction to levy fees under section 234E if intimation issued prior 1st June, 2015. [S. 200A]

S. 153A : Assessment–Search-Additions made by AO were beyond scopebecause no incriminating material or evidence was found during course of search so as to doubt-Action of AO was based upon conjectures and surmises and hence, addition made was not sustainable in eyes of law [S. 132 , 143(3)]

S. 132(4) : Search and seizure–Statement on oath -Income from undisclosed sources—Unexplained investments—Excess stock-Addition on Gross profit earned and sales of unaccounted stock- Matter seta side to the AO to examine the reconciliation statement filed before the lower authorities. Further held that Assessee’s profit in earlier year was less than year under consideration meaning thereby his Gross Profit was higher than earlier years therefore, in such circumstances assessee’s contentions could not be denied. [S. 69, 132, 145]

S. 40(a)(ia) : Amounts not deductible – Deduction at source – Contractors – No Express or implied contract between assessee and maistries – No contract between assessee and maistries and payments to labour through maistries does not attract tax deduction at source [ S.194C ]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Testing fee to Kema, Netherlands-Payment made to non-resident-Where knowledge of testing is not made available to assessee, same could not be considered as fee for technical services and assessee is not liable to deduct tax at source. [S. 195 ]

S. 36(1)(iii) : Interest on borrowed capital-Finance charges shall not be deductiblewhere the activity carried out by assessee was as investment activity. [S. 37(1)]

S. 14A : Disallowance of expenditure-Exempt income-If there were funds available both interest-free and over draft and/or loans taken, then a presumption would arise that investments would be out of interest-free fund generated or available with company, if interest-free funds were sufficient to meet investments. [R. 8D]

S. 12AA : Registration–Trust or institution-Procedure for registration of trust-CIT(E) has to examine the objects of the trust and if they are found to be charitable, the assessee deserves to be granted registration The quantum of the genuineness of the activity can be examined only after the trust comes fully into operation.

S. 12AA : Registration–Trust or institution-CIT(E) has to examine the objects of the trust and if they are found to be charitable, the assessee deserves to be granted registration. [S. 12A]