S.14A: Disallowance of expenditure-Exempt income-Interest-free funds-Non-interest-bearing funds were more than the investment made in tax-free securities; it would be presumed that the investment made by the assessee would be from its interest-free funds and, thus, no disallowance under section 14A could be made-Order of Tribunal affirmed. [S.260A, Rule 8D]

S. 10A: Free trade zone-STP Unit-New infrastructure, plant and machinery, software and separately recruited workforce-Undertaking not formed by splitting up or reconstruction of existing business-Deduction allowable-Order of Tribunal affirmed. [S. 10A(2), 260A]

Direct Tax Vivad Se Viswas Act, 2024.
S 91 : Filing of declaration and particulars to be furnished-Prior tax position revived when assessee does not comply with provisions / requirements of DTVSV Act 2020 and hence eligible under DTVSV Act 2024.[DTVSV Act, 2020, S. 4(6), 5(1)Art. 226]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-When the subject matter of the penalty, which was the very basis on which criminal proceedings had been launched, was set aside, criminal proceedings could not be allowed to continue.[S.271(1)(c), 277]

S. 276B : Offences and prosecutions-Failure to pay to the credit tax deducted at source-Revenue had accepted statutory compounding fee under section 279 in relation to alleged offences under sections 276B and 278B-Continuation of criminal proceedings after such compounding constituted abuse of process and liable to be quashed. [S. 278B, 279, Art.21, 226]

S. 269ST: Mode of undertaking transactions-Intimation of heavy cash transaction to jurisdictional Income Tax Authorities in civil recovery suits pursuant to Supreme Court guidelines-Assessee could not be compelled to reveal his PAN to the debtors. [S.271DA]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Search and seizure-Inspection of seized jewellery-Supply of reasons to the assessee not required under rule 112(13)-Power to reopen sealed package not predicated on information in possession of Revenue-Notice for inspection valid. [S. 132, Income-tax Rules, 1962, r. 112]

S. 260A: Appeal-High Court-Review petition-Mistake apparent from record-Assessment-Processing of return-No error apparent when the matter was fully heard, and directions were issued to process returns in accordance with law-Review not maintainable-Assessment-Processing of return.[S.139, 143(3), 260A (7)]

S. 245 : Refunds-Set off of refunds against tax remaining payable-Adjustment of refund against demand cannot be made when prior demand is not evidenced by a valid demand notice/intimation-Foreign tax credit-Petitioner was entitled to credit of foreign taxes paid/withheld in UK as reflected in Form-16, notwithstanding that claim was not separately entered under Relief under Section 90/91 field of return-Held, yes-Whether demand for Assessment Year 2010-11 was to be deleted and refund, if any, was to be granted. [S.90, 91, 143(1), 156, Art. 226]

S. 244A: Refund-Interest on refund-Technical glitch causing TDS credit not reflected in e-filed revised return though appearing in Form 26AS-Assessee promptly informed Assessing Officer and lodged complaint with CPC-Denial of interest by Assessing Officer on ground of lapse by assessee-Not justified-Under section 244A (2), power to exclude any period attributable to assessee vests only in Principal Chief Commissioner or Commissioner, not Assessing Officer. [S. 154]