S. 115JB: Company-Book profit-Minimum Alternate Tax-Electricity company governed by the Electricity Supply Act, 1948-Provisions of section 115JB not applicable. [S.260A, Electricity Supply Act, 1948]

S. 115JA : Company-Book profit-Minimum alternate tax-Provision for doubtful debts-Amount receivable-Not a liability or reserve-Addition to book profit not permissible.[S.260A]

S. 115BAA: Tax on income of certain domestic companies-Concessional tax regime-Delay of 15 days-Condonation of delay in filing Form 10-IC-Filing return within the due date under section 139(1) was not a condition precedent for claiming benefit under section 115BAA-Order rejecting application for condonation was set aside, and delay in filing Form 10-IC was condoned. [S. 119, 139(1)., Art. 226]

S. 115BAA : Tax on income of certain domestic companies-Concessional tax regime-Form 10-IC-Condonation of delay-Conditions prescribed by CBDT Circular complied with-Delay condoned.[S. 119, 143(1), Rule 21AE, Form 10-IC, Art. 226]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-TPO failed to follow any prescribed method for determining ALP-Mistake could not be rectified in second innings-Appeal by Revenue-Low tax effect-CBDT Circular dated 15-3-2024-Monetary threshold of Rs. 2 crore applicable. [S.92B, 260A, 268A]

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Revocation of approval-Non-compliance with jurisdictional parameters in reopening proceedings; accordingly, impugned notification revoking approval and the reopening notice not interfered with. [Art. 226]

S. 79: Carry forward and set off losses-Change in shareholdings-Companies in which the public are not substantially interested-Company undergoing CIRP-Principal Commissioner had notice under section 79 and did not make any submissions when the resolution plan was approved; denial of carry forward of losses could not be sustained; further, availability of such losses would have been a factor considered by the resolution applicant in submitting its proposal, and therefore assessment proceedings were quashed and set aside. [The Insolvency and Bankruptcy Code, 2016, 2, 31, Art. 226]

S. 68: Cash credits-Search and seizure-Cash found-Failure to correlate seized cash with loose papers-Addition justified-Order of Tribunal affirmed.[S.260A]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Short deduction of tax at source-Merely a short deduction of TDS by assessee under section 194C, and persons to whom payments were made by assessee had paid taxes on such payments, Assessing Officer could not have invoked provisions of section 40(a)(ia) and disallowed expenses claimed by assessee-Order of Tribunal affirmed. [S. 194C; Second proviso, 194I, 260A]

S. 37(1): Business expenditure-Infrastructure fee-Advertising receipts-Tribunal was justified in restricting deduction to 5 per cent of actual receipts in accordance with the agreement and not on the gross advertising bill-Order of Tribunal affirmed. [S.145, 260A]