S. 4: Charge of income-tax-Capital or revenue-Grants-Capital reserve account-Road project-Infrastructure development-Grants/contributions from State Government for completion of road projects undertaken by it on BOT basis-Grants/contributions were a capital contribution by State Government towards the cost of projects-Not taxable as revenue receipts. [S. 28(i), 145]

S. 2(22)(e): Deemed dividend-Refundable rental security deposit from tenant-Cannot be assessed as deemed dividend-Matter remanded.

S. 2(22)(e): Deemed dividend-Deemed dividend-Loan to firm where partners held substantial interest in lender company-Assessee not a shareholder-Advances are not chargeable as deemed dividend.

S. 2(14)(iii): Capital gains-Land beyond 8 km from municipal limits-Held, not a capital asset-Agricultural income supported by records-Additions deleted. [S. 10(1), 153A]

S. 272A: Penalty-Failure to answer questions-Sign statements-Furnish information-Defaulted in timely furnishing of information but ultimately submitted all requisite details which were duly considered in framing assessment-lapse was only a technical/venial breach-Penalty was not justified.[S. 10(23C), 139, 272A(1)(d)]

S.271D: Penalty-Takes or accepts any loan or deposit-Limitation-Penalty proceedings under section 271D were initiated during reassessment by issuing a show-cause notice on 17-8-2022-Penalty order was passed on 29-3-2023 beyond the limitation period under section 275(1)(c)-Penalty was barred by limitation and was not sustainable. [S. 148, 269SS, 275(1)(c)]

S. 271(1)(c) : Penalty-Concealment-Additional evidence obtained under RTI Act-Matter remanded.[S.80IB(10)

S. 270A:Penalty for under-reporting and misreporting of income-
Not specifying the charge, whether it was for under-reporting or misreporting of income-Penalty order was void ab initio and not sustainable in law-Penalty was deleted. [S. 45, 54F, 274]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Donations-CSR activities-Allowed deduction under section 80G-Revision order was set aside. [S.80G, 143(3)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Depreciation-Road Project-Building, operating and transferring a section of national highway-Road construction project-Intangible asset-Eligible depreciation-Mercantile system of accounting-Negative grant-Depreciation on negative grant which was to be paid to NHAI-Depreciation allowable-Revision order set aside.[S. 32 143(3),145]