S. 68: Cash credits- Conversion of private limited company into LLP – The transfer of share capital and reserves to partners’ accounts upon conversion – The addition was not justified since the nature and source of the credit were explained and not unexplained. [S. 47(xiiib)(f), 115BBE]

S. 68 : Cash credits-Firm -Partners-Once partners’ identity, creditworthiness, and genuineness of capital contribution are established through evidence, addition u/s. 68 cannot be made in the firm’s hands, as the firm is not required to explain the source of partners’ funds. [S. 2(31)(iv)]

S.43CA: Transfer of assets- other than capital assets-Full value of consideration-stock in trade-Agreement value-Stamp valuation Difference between SDV and agreement value was less than 5 per cent-Addition is deleted-Change of opinion-Reopening is not justified. [S. 50C, 147, 148]

S. 40A(2) : Expenses or payments not deductible-Excessive or unreasonable-Consultancy charges paid to related party-No comparable instances cited by AO-Disallowance is deleted. [S. 40A(2)(b)]

S. 11 : Property held for charitable purposes – Excess expenditure over income-Accumulation of income-Applied charitable purpose – Denial of exemption is not valid. [S. 11(1)(a), 12A]

S. 11 : Property held for charitable purposes – Accumulation of income-Amendment by Finance Act, 2022, restricting accumulation applies prospectively from 1-4-2022- Trust could validly utilize accumulated income of earlier years up to 31-3-2023 within original time window. [S. 11(3)(c)]

S. 4 : Charge of income-tax – Capital or revenue – Compensation received for under performance of wind turbine generators (WTGs)- Capital receipt. [S.28(i)]

S. 151A: Face less assessment scheme – Reassessment – Faceless jurisdiction – Manual DIN – Reassessment held void ab initio – Jurisdictional AO issued notice instead of Faceless AO – Assessment order manually issued without computer-generated DIN – Proceedings invalid. S. 147, 148 151, CBDT Circular No. 19/2019 ]

S. 69A : Unexplained money – Rough diary notings – Internal circulation of funds –Statement in the Course of search – Statement retracted – Addition unsustainable.[ S. 132, 132(4), 132(4A) ]

S. 45 : Capital gains – Alleged NOC receipts – Loose sheets – Statement in the Course of search – Statement retracted – No corroboration – Additions deleted. [ S.132, 132(4), 132(4A) ]