S.14A : Disallowance of expenditure-Exempt income-salaries paid to the employees of the treasury department-Allocaation of eexpenses on the basis of area occupied by the department-Held to be reasonable-Book profit-Adjustment of disallowance under s. 14A is not required to be made in the book profit for MAT liability. [S.115JB, R.8D]

S. 12AB: Procedure for fresh registration-Religious trust-Trust for the benefit of particular community-Jain community and to propagate Jainism-Order rejecting the application is affirmed. [S. 11, 12, 12AB(4) 13(1)(b)]

S. 11 : Property held for charitable purposes-Revised claim by rectification application-Filed within the time prescribed u/s 139(5)-No intimation was issued u/s 143(1)-Denial of exemption is not valid.[S. 139(5) 143(1), 154(8)]

S. 10 (23C): Educational institution-Wrong sub section is mentioned in the return-Mistake of counsel-Exemption is allowed-Non foling of audit report-Not applicable to university-Entitle to eexxemption-Delay of 691 aand 706 days-Mistake of counsel-Delay is condoned. [S. 10(23C)(iiiab), 12A, 44AB,253(5), 254(1)

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Not dependent agent-No substantial transaction-Income is not chargeable to tax in India-Fees for technical services-Reimbursement of salaries of seconded employees-Tax deducted at source-issue is remitted to the AO for fresh adjudication as per law-DTAA-India-USA.[S.90, Art, 12(4)]

S. 5 : Scope of total income-Income-Accrual-Notional interest-Waiver of interest on Compulsorily Convertible Debentures-Interest waived before the end of financial year-Commercial expediency-No addition can be made on account of interest income on notional basis. [S. 4, 143(3) 145]

S. 13A:Political parties – Delay in filing return – Cash donations exceeding limit – Strict compliance required –Not entitle to exemption if the return is filed after due date – Exemption denied – Appeal dismissed . [S. 13A(d), 139(1), 139(4), 139(4B), 143(3), Representation of People Act, 1951, S. 29A]

S. 271(1)(c) : Penalty – Concealment – Information from sales-tax authorities – Bogus purchases – Hawala parties – Estimated additions – Quantum restricted to 12. 5% of bogus purchases – Penalty is leviable . [ S.69C ] S. 271(1)(c) : Penalty – Concealment – Information from sales-tax authorities – Bogus purchases – Hawala parties – Estimated additions – Quantum restricted to 12. 5% of bogus purchases – Penalty is leviable . [ S.69C ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Central Circle – Notice issued by jurisdictional Assessing Officer (JAO ) rather than the Faceless Assessment Officer (FAO)- Notice and consequential order under section 148A(d) is quashed and set aside – Liberty is granted to the Revenue to seek revival if the Supreme Court later reverses the decision in Hexaware Technologies Ltd . [ S. 148 , 148A(b), 148A(d) , 151A Art , 226 ]

S. 271(1)(c) : Penalty – Concealment – Notice must specify the charge – Notice must be precise and there should be no room for ambiguity – Veena Estate (P.) Ltd v. CIT [2024] 158 taxmann.com 341/ 461 ITR 483 (Bom)( HC) , distinguished- Order of Tribunal is affirmed .[ S. 260A ]