S. 69A : Unexplained money-Post-demonetisation deposit of old currency notes-Cash book balance insufficient to explain deposit – Failure to explain the source – Addition was affirmed.[S. 260A]

S. 69A : Unexplained money – Denominations – Details not maintained – Nature of source of cash deposit was not explained satisfactorily – SLP of assessee dismissed. [Art. 136]

S. 45 : Capital gains-Accepted cost of acquisition – Difference between intrinsic value of shares and amount paid by assessee cannot be taxed as perquisites – Order of Tribunal deleting the addition is affirmed. [S. 2(24)(iv), 260A]

S. 40A(3) :Expenses or payments not deductible-Cash payments exceeding prescribed limits-Payments to agents cannot be disallowed – Order of Tribunal set aside. [ITR, 1962 R. 6DD, Indian Contract Act, 1872, S. 182.]

S. 37(1) : Business expenditure-Foreign exchange rates Expenses incurred on account of foreign exchange fluctuation and interest thereon in respect of foreign currency loans-Allowable business expenditure-Order of Tribunal set aside-Travelling expenses-Expenses incurred towards foreign tour of executives accompanied by their spouses-Major portion of claim allowed by Commissioner (Appeals)-Miniscule amount being involved order of Tribunal, affirmed.

S. 37(1) : Business expenditure-Provision for warranty – Deletion of addition by the Tribunal is affirmed.

S. 119 : Central Board of Direct Taxes- Circular – Condonation of delay – Filing of return of loss – Genuine hardship – Delay of 5 months in filing return due to bona fide professional advice by Chartered Accountant – Assessee should not suffer grave hardship for a professional’s mistake – Circular No. 9 of 2015 – Delay was condoned – CBDT’s rejection order set aside- Directed that the return filed on 30th March 2019 be treated as filed in time, and permitted assessment to be completed under section 153(1B) of the Act . [S. 72, 80, 119(2)(b), 139(1), 139(3), 153(1B), Art. 226 ]

S. 147 : Reassessment – Information from third-party search – Accommodation entries – Cash credits -Section 153C not triggered, reopening u/s 147 is valid-On merits, addition based mainly on untested third-party statement without cross-examination requires fresh adjudication by CIT(A). [S. 68, 132(4), 133(6), 148, 151, 153C, ITAT Rule, 1963 ,R. 27]

S.115BAA : Tax on income of certain domestic companies – Determination of tax in certain cases – Option exercised under section 115BAA – Rate of tax applicable – Long term capital gains – Company opting for taxation under section 115BAA is liable to pay tax at 22% on total income including long-term capital gains and not at 20% as per section 112. [S. 45 , 112, 143(1), Form 10IC ]

S. 275 : Penalty – Bar of limitation – Recording of satisfaction-Cross objection- CBDT Circular binding on department -Period of limitation is to be reckoned from the date of recording of satisfaction by the AO in the assessment order and not from the date of notice issued by the Joint/Additional CIT. [ S.119, 269SS , 271D, 271E ,271AAA, 275(1)( c) ]