S. 271(1)(c) : Penalty – Concealment – Disallowance of deduction- Method of accounting – Plausible interpretation of law – No malafide intention – Disclosed all relevant facts and no false statement –Penalty is deleted . [S. 43B , 145 , 260A ]

S. 4 : Charge of income-tax – Capital or revenue – Sales Tax Incentive – Purpose test – Incentive for setting up industrial unit in backward area – Sales tax incentive under 1979 and 1983 Schemes is capital receipt, not chargeable to tax.[ S. 28(i), 43B, 1979 Scheme . 1983 Scheme]

S. 11 : Income from property held for charitable or religious purposes – Delay in e-verification of audit report – Audit report in Form 10B filed in time- E-verification delayed due to COVID- Delay is not intentional – Delay of 101 or 254 days within permissible limit – Rejection of condonation against principles of substantive justice – Procedural lapses should not override substantive justice, especially when there was no mala fide intent or negligence by the petitioner- Rejection order is quashed – Delay condoned . [S. 12A, 12AA, 80G , Form No 9A, form No 10B , Art.226 ]

S. 268A : Appeal – Instructions -Circulars – Monetary limits -2 crores- Applicability of revised CBDT monetary limits (Circular No 3 of 2018 dt 11-7 2028 (2018) 405 ITR 29 ( St), Circular 9 of 2024 , dated 17 th September , 2024 (2024) 468 ITR 1 ( St))- Exceptions Apply Prospectively – Pending Appeals Covered by revised threshold – Appeal of Revenue is dismissed.[ S.260A ]

S. 45(4) : Capital gains – Distribution of capital asset – Dissolution of firm – Introduction of new partner – Amount received by existing partner for sacrificing his profit-sharing ratio – Realignment of share ratio – No transfer of asset – No capital gain taxable on relinquishment of share ratio-Post amendment , 2021 , Finance Act , 2021 . [S. 2(14), 2(47),9B , 45]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Accumulation of income-Corpus donation-Issue dealt in revision proceedings was unrelated in character from issue of corpus donation received by assessee which was dealt in re-assessment proceedings-Revision order was beyond period of two years-order is barred by limitation-Revision is quashed and set aside.[S. 11, 12A 143(1), 147, 148]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Government-funded educational institution-Assessing Officer has allowed the exemption based on a correct appreciation of facts and applicable law-Revision order is set aside. [S. 10(23C)(iiiab)]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Ex-parte assessment order-Foreign tax credit-Order is set aside-DTAA-India-USA [S. 90, 139(1), Form No.67, Art. 25]

S. 220 : Collection and recovery-Assessee deemed in default-No order or notice of demand was issued-Not liable to pay interest. [S.156, 220(2)]

S. 201 : Deduction at source-Failure to deduct or pay-Deducting lower tax in earlier months of financial year-Short fall is made good in next month-Not liable to pay interest. [S. 192(3), 201(IA)]