S. 132 : Search and seizure-Reason to believe must exist at time of issue of warrant of authorisation for search-Department must give specific details to justify search-Merely on basis of warrant of authorisation-Search and seizure invalid-Survey-Notice of survey issued pursuant to search is not valid-Interpretation Of Taxing Statutes-Strict constructions.[S. 131(IA), Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Delay in filing return-Condonation of delay-National Company Law Tribunal-Revised books of account-Genuine hardship-Power vested in Authority to be judicially exercised-The assessee could file before the jurisdictional Assessing Officer physical returns of income based on books of account revised under section 130(2) of the 2013 Act, as taken on record by the National Company Law Tribunal for the assessment years 2015-16 to 2020-21 within the time stipulated in this order. [S. 119(2)(b). 139(4), Companies Act, 2013, S. 130, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Intra-Group services-Application of Arm’s Length Price adjustment resulting in reduction of income chargeable to tax-Transfer pricing provisions cannot be applied.[S.92(1), 92(3), 92B, 260A]

S. 80-O : Royalties-Foreign enterprises-Royalty or fees received from foreign entity-Mere claim of sending newspaper cuttings does not amount to proof of sharing commercial expertise-No evidence for provision of information to foreign entity-Deduction rightly rejected by Tribunal.[S. 260A]

S. 43B : Deductions on actual payment-Electricity Duty on sale of power payable to Government adjusted against sums due to assessee from Government-Entitled to deduction-Produce Certificate from Chartered Accountant to establish adjustment made within time as claimed. [Art. 136]

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-No payments for purchase of shares made in cash-Disallowance is not attracted.[S.255(4), 260A]

S. 37(1) : Business expenditure-Capital or revenue-Software Development expenses-Product abandoned on becoming obsolete due to development in technology-No enduring benefit-Allowable as revenue expenditure.[S. 260A]

S. 37(1) : Business expenditure-Capital or revenue-Software Development expenses-Product abandoned on becoming obsolete due to development in technology-No enduring benefit-Allowable as revenue expenditure-SLP of Revenue is dismissed.[Art. 136]

S. 32 : Depreciation-Carry forward and set off of unabsorbed depreciation-Amendment of Section 32(2) by Finance Act, 2001-Unabsorbed depreciation or part thereof not set off till Assessment year 2002-03-Carry forward and set off permitted without limit.[S. 32(2) 260A]

S. 32 : Depreciation-Carry forward and set off of unabsorbed depreciation-Amendment of Section 32(2) by Finance Act, 2001-Unabsorbed depreciation or part thereof not set off till Assessment year 2002-03-Carry forward and set off permitted without limit-High Court affirmed the order of the Tribunal-SLP of Revenue is dismissed [S. 32(2) Art. 136]