S. 69C: Unexplained expenditure -Unexplained expenditure – Bogus purchases – Sales accepted and books of account not rejected under section 145(3) –Furnished books of account, purchase invoices, payment details through banking channels and other supporting evidence – Addition based merely on non-response of suppliers to notices under section 133(6) and cancellation of GST registrations – Once corresponding sales were accepted, purchases could not be disbelieved or disallowed in entirety – Finding of Tribunal based on appreciation of evidence was a finding of fact – No substantial question of law arose – Revenue’s appeal dismissed. [S. 69A, 69C, 115BBE, 133(6), 145(3), 260A.]

Interest-tax Act, 1974

S. 2(7) : Interest-Subsidy received from RBI-Export Credit-Subsidy Scheme-Not interest-Not chargeable to tax. [S. 4, 260A, Reserve Bank of India Act, 1934(2 of 1934) S.42(IB)]

Direct Tax Vivad Se Vishwas Act, 2020
S. 3: Amount payable by declarant-Belated amendment of appeal memo after filing declaration under DTVSV Scheme was inadmissible-Amount payable by declarant-Case was treated as non-search case, amount payable under DTVSV Scheme was to be calculated at 100 per cent and not 125 per cent. [S.10(38), 45 68, 132, 271(1)(c), CBDT Circular No. 21 of 2020, Art. 226]

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015]
S. 43: Penalty-Failure to furnish in return of income, an information or furnish inaccurate particulars about an asset-Non-disclosure of foreign investment in Schedule FA-Investment held in assessee’s name only for administrative convenience and disclosed by husband-Penalty deleted-Order of Tribunal affirmed. [S.260A]

S. 278B: Offences and prosecutions-Companies-Liability of director-Part-time director-The criminal complaint against assessee was quashed and set aside. [S. 276C(2), 278B(2)]

S. 278B: Offences and prosecutions-Companies-Offences by firms-Impleadment of partners-Sessions Judge erred in allowing application for impleadment of partners; accordingly, order directing impleadment of partners was set aside. [The Code of Criminal Procedure, 1973, 319.]

S. 271(1)(c): Penalty-Concealment-Failure to record proper satisfaction regarding the applicable limb of the section-Penalty order invalid.[S. 10(23C)(vi)]

S. 271(1)(c): Penalty-Concealment-Bar of limitation for imposition-Pendency of quantum of appeal before Tribunal-Under section 275 as it stood prior to 1-4-2025, penalty order could not be passed during pendency of appeal against quantum assessment before ITAT; accordingly, ad-interim relief was granted restraining Revenue from taking any steps pursuant to penalty order. [S.254(1), 275(1)(a), Art. 226]

S. 271(1)(c) : Penalty-Concealment-Charitable trust-Bona fide claim of exemption under section 11-No concealment or furnishing of inaccurate particulars-Order of Tribunal set aside. [S. 11, 12A, 260A]

S. 271(1)(c): Penalty-Concealment-Validity of notice-Failure to specify charge-Notice invalid-Order of Tribunal affirmed. [S.260A]