S.43CA: Transfer of assets-other than capital assets-Full value of consideration-stock in trade-Agreement value-Stamp valuation-Allowing 10 per cent tolerance band is curative and applies retrospectively-No addition was warranted in case of assessee, where difference between DVO value and sale consideration was within permissible limit for assessment year 2018-19.[S.50C]

S.43B: Deductions on actual payment-Liabilities disallowed in earlier year-Paid during year-Allowable on furnishing payment evidence, while addition for balance amount without supporting evidence was to be sustained.

S. 41(1): Profits chargeable to tax-Remission or cessation of trading liability-Provision for liquidated damages-Settled under VSV Scheme, 2024-Not allowed deduction in earlier years-Reversal of provision-Cannot be taxed under section 41(1) of the Act. [VSV Scheme, 2024]

S. 41(1): Profits chargeable to tax-Remission or cessation of trading liability-Sundry creditors-Confirmation from parties-Additional evidence-The matter was restored to the file of the Assessing Officer for fresh adjudication.[S. 254(1)]

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. 40(a)(ia): Amounts not deductible-Deduction at source-Building contractor-Capitalised the expenditure-Not disallowable.[S. 30 to 38, 143(1)(a), 194C]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Job work-Furnished Form 16A-Addition was deleted.[Form No 26AS]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission payment outside India-: Income deemed to accrue or arise in India-Commission paid to non-residents for services rendered outside India is not taxable in India; hence, the assessee is not liable to deduct TDS under S. 195. [S. 9(1)(i), 195]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Reinsurance premium ceded to non-resident reinsurers (NRRs) is not taxable in India under the Income Tax Act or the applicable DTAA; therefore, disallowance under S. 40(a)(i) for non-deduction of TDS under S. 195 does not arise. [S.195]

S. 40(a)(i): Amounts not deductible-Deduction at source-Non-resident-Business profits-Canvassing orders and facilitating export transactions-Business income accruing outside India-Not liable to deduct tax at source-No disallowance can be made.[S.9(1)(i), 195, Article 7 of the OECD Model Convention]