S.80IA: Industrial undertakings – Enterprises engaged in infrastructure development -Derived – Interest income on fixed deposits kept for contractual obligations and Interest on wrongful deduction of TDS refund – Eligible for deduction as profits derived from infrastructure facility. [ S. 56 ,80IA(ii), 254(2), 260A , Art.226 ]

S. 69C : Unexplained expenditure – Bogus purchases -Information from sales tax department – Bogus accommodation entries – Purchases – Payments through banking channels – Sales accepted – Addition restricted to 5 percent – PCIT v. Kanak Impex (India) Ltd. [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) distinguished. [ S. 143(3) ]

S. 69C : Unexplained expenditure – Bogus purchases – Addition restricted to 4% – Tribunal held that since purchases were supported by invoices, bank statements, stock register, and no defect was found in books or sales, only profit element could be added. High Court decision in PCIT v. Kanak Impex (India) Ltd. [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) distinguished- Appeal of revenue was dismissed .

S. 69C : Unexplained expenditure – Bogus purchases – Addition made on estimated basis of 25% of purchases deleted – Purchases supported by bills, stock register, delivery challans and bank payments – Supplier appeared before AO and confirmed sales – ITAT held that once purchases are corroborated by evidence and vendor’s statement, no addition could be sustained – Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished . [ S. 68 ]

S. 69C : Unexplained Expenditure – Bogus Purchases – Addition unsustainable when purchases supported by documents, payments through banking channel, sales accepted, and no cross-examination allowed – VAT authorities accepted purchases-Addition was deleted -Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished .[ S.133(6), 144 ]

S. 69C : Unexplained expenditure -Bogus Purchases – Only profit element to be taxed- Addition restricted to 12.5% of alleged bogus purchases- Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished . [ S. 133(6), 147 , 148 ]

S. 69C : Unexplained expenditure -Bogus Purchases – Hawala – Accommodation entries – Purchases duly supported by bills, cheque payments, confirmations, and accepted sales cannot be treated as bogus. Disallowance of entire purchases unjustified- Disallowance deleted- Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished . [ S. 37(1) , 44AB , 133(6) ]

S. 69C : Unexplained expenditure -Bogus Purchases – Estimation of profit element – When purchases were supported by bills, bank payments and sales not disputed, addition restricted to 12.5% of alleged bogus purchases; Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished and held not applicable. [ S. 147 , 148 ]

S. 255 : Income tax Appellate Tribunal–Additional premises for the functioning of Court Rooms–Interim order of the High Court dated 28th June, 2000 allotting the premises to ITAT for the functioning of additional five court rooms is affirmed [S. 254, Art. 226]

S. 144C : Dispute Resolution Panel – Draft Assessment Order – Eligible assessee – Not an eligible assessee if TPO makes no variation – Assessment order without jurisdiction.- Quashed assessment order. [S. 92CA(3), 144C(15)(b) , Art. 226 ]