S. 69A: Unexplained money-Income from Undisclosed Sources-Cash deposits-Partner-Firm-Addition upheld where explanation regarding capital contribution by partners was unsupported by evidence. [S. 254(1)]

S. 44AF : Retail business-Computation-Business income-Presumptive taxation-Return filed under section 44AF cannot be treated as defective for non-furnishing of particulars required under section 139(9)-Entitled to the consequential refund. [S. 44AF, 139(9), Art. 226]

S. 10(23BBA): Income of any body or authority-Exemption is available only to the statutory body or authority administering religious institutions and not to the institutions themselves. [S. 11, 12, 12A, Art. 226]

S. 271D: Penalty-Takes or accepts any loan or deposit-Failure to record satisfaction-Penalty order was quashed-SLP of revenue dismissed on account of delay of 359 days and also on merits. [S. 269SS, Art. 136]

S. 271AAB: Penalty-Search cases-Period of limitation-Penalty initiated in the assessment order, which was carried in appeal to the Commissioner (Appeals) and the Tribunal-Limitation governed by section 275(1)(a) and not the residuary clause (c)-Penalty order passed within six months of receipt of the Tribunal’s order is within limitation. [S. 132(4), 275(1)(a), 275(1)(c), Art. 226]

S.270AA: Immunity from imposition of penalty-Application for immunity from penalty was rejected without considering the assessee’s contentions, or the reasons could not withstand judicial scrutiny and therefore is liable to be set aside. [S. 143(1), 270A(9), Art . 226].

S. 270A: Penalty for under-reporting and misreporting of income-Deductions claimed under binding High Court precedent subsequently overruled-Bona fide explanation and full disclosure-Assessed income not exceeding processed income-Penalty unsustainable-Ad-interim stay granted.[S. 270A(2), 270A(6), 264, Art. 226]

S. 264 : Commissioner-Revision of other orders-Condonation of delay-Revision filed nearly seven years after rejection of the rectification application uploaded on the portal-Institutional assessee expected to be diligent-No sufficient cause-Revision rightly rejected. [S. 10(25), 154, Art. 226]

S. 264: Commissioner-Revision of other orders-Exemption under section 11 denied due to inadvertent and bona fide punching errors in the return processed under section 143(1)-Assessee has the discretion to seek revision instead of appeal-Commissioner obliged to consider and grant relief even for an error committed by the assessee itself. [S. 11, 143(1), 154, 246A, Art. 226]

S. 264: Commissioner-Revision of other orders-Tax on long-term capital gains-Precedent-Principal Commissioner was bound to follow such decision and could not deviate on the ground of departmental non-acceptance-Revision order was unsustainable and set aside. [S. 45, 50, 112, Art . 226]