S. 80G : Donation-CBDT, vide Circular No. 8 of 2022 dated 31-3-2022, extended time limit with respect to both existing trusts and new trusts for registrations under sections 10(23C), 12A and 80G(5)-CBDT circular did not grant extension to new trusts for filing forms for application-Clause 5(ii) of circular No. 6/2023, dated 24-5-2023 was arbitrary and violative of article 14 of Constitution of India and accordingly, would be ultra vires Constitution. [S.10(23C), 12A, 80G(5), 119(2)(b), Art. 14, 226]

S. 69 : Unexplained investments-Photocopy of an alleged agreement to sell-Addition is not justified-Order of Tribunal deleting the addition is affirmed.[S.260A]

S. 68 : Cash credits-long term capital gains-Penny stock-Bogus claim-Sulabh Engineers & Services Ltd-Order of Tribunal is affirmed-High Court cannot be converted into an Appellate Tribunal to examine the factual issue which was not placed before the Tribunal or lower Authorities-No substantial question of law. [S. 45, 260A]

S. 68 : Cash credits-Principle of natural justice-Adjournment application is not considered-Order is set aside [S. 143(3), Art. 226]

S. 68 : Cash credits-Unsecured loans-Statement in the course of search-Praveen Kumar Jain-Accommodation entries-Confirmation is filed-Loan received and repaid by account payee cheque-Order of Tribunal deleting the addition is affirmed.[S. 260A]

S. 68 : Cash credits-Long term capital gains from equities-Penny stock-Accommodation entries-Survey-Report of Investigation Wing-Delay of 303 days-Explanation offered by the Revenue is held to be not sufficient to condone the delay-SLP of Revenue is dismissed. [S. 10(38), 45 Art.136]

S. 68 : Cash credits-Statement of Directors-High Court affirmed the order of the Tribunal deleting the addition-SLP of Revenue is dismissed.[S. 132, Art. 136]

S. 56 : Income from other sources-Share premium-Not received any consideration for allotment of shares in previous year relevant to current assessment year-Deletion of addition by the Tribunal is affirmed-Assessing Officer has no jurisdiction to substitute NAV method of assessing valuation of shares, once assessee has exercised option of a DCF valuation method as per rule 11UA(2)-Order of Tribunal is affirmed. [S.56(2)(viib), 260A, R.11UA(2)]

S. 54F : Capital gains-Investment in a residential house-Surrender of tenancy-Stamp duty value-Unexplained investment-Show cause notice-Not an empty formality-Entitle to exemption-Assessment order is quashed. [S. 45, 56(2)(x)(a), 56(2)(x)(b), 115BBE, 143(3), 144B Art. 226]

S. 44BB : Mineral oils-Computation-Non-resident-Royalty-supply/lease/hire of rigs to be used for drilling and exploration of mineral oils-Amount received is covered under provisions of section 44BB and taxable on gross/presumptive basis at rate of 10 per cent-DTAA-India-Malaysia.[S.9(1)(vi), 115A, 260A, art. 12]