S. 80HHC : Export business-When certain profit is to be excluded from claim of deduction under sections 80HH, 80I and 80HHC, it is not gross profit but net thereof, that is, gross profit minus expenditure incurred for earning such profit which should be excluded-Tax effect is below threshold limits-SLP of Revenue is dismissed.[S. 80HH, 80I, 268A, Art. 136]

S. 80G : Donation-CBDT, vide Circular No. 8 of 2022 dated 31-3-2022, extended time limit with respect to both existing trusts and new trusts for registrations under sections 10(23C), 12A and 80G(5)-CBDT circular did not grant extension to new trusts for filing forms for application-Clause 5(ii) of circular No. 6/2023, dated 24-5-2023 was arbitrary and violative of article 14 of Constitution of India and accordingly, would be ultra vires Constitution. [S.10(23C), 12A, 80G(5), 119(2)(b), Art. 14, 226]

S. 69 : Unexplained investments-Photocopy of an alleged agreement to sell-Addition is not justified-Order of Tribunal deleting the addition is affirmed.[S.260A]

S. 68 : Cash credits-long term capital gains-Penny stock-Bogus claim-Sulabh Engineers & Services Ltd-Order of Tribunal is affirmed-High Court cannot be converted into an Appellate Tribunal to examine the factual issue which was not placed before the Tribunal or lower Authorities-No substantial question of law. [S. 45, 260A]

S. 68 : Cash credits-Principle of natural justice-Adjournment application is not considered-Order is set aside [S. 143(3), Art. 226]

S. 68 : Cash credits-Unsecured loans-Statement in the course of search-Praveen Kumar Jain-Accommodation entries-Confirmation is filed-Loan received and repaid by account payee cheque-Order of Tribunal deleting the addition is affirmed.[S. 260A]

S. 68 : Cash credits-Long term capital gains from equities-Penny stock-Accommodation entries-Survey-Report of Investigation Wing-Delay of 303 days-Explanation offered by the Revenue is held to be not sufficient to condone the delay-SLP of Revenue is dismissed. [S. 10(38), 45 Art.136]

S. 68 : Cash credits-Statement of Directors-High Court affirmed the order of the Tribunal deleting the addition-SLP of Revenue is dismissed.[S. 132, Art. 136]

S. 56 : Income from other sources-Share premium-Not received any consideration for allotment of shares in previous year relevant to current assessment year-Deletion of addition by the Tribunal is affirmed-Assessing Officer has no jurisdiction to substitute NAV method of assessing valuation of shares, once assessee has exercised option of a DCF valuation method as per rule 11UA(2)-Order of Tribunal is affirmed. [S.56(2)(viib), 260A, R.11UA(2)]

S. 54F : Capital gains-Investment in a residential house-Surrender of tenancy-Stamp duty value-Unexplained investment-Show cause notice-Not an empty formality-Entitle to exemption-Assessment order is quashed. [S. 45, 56(2)(x)(a), 56(2)(x)(b), 115BBE, 143(3), 144B Art. 226]