S. 245 : Refunds-Setting off against tax due-Stay application- Pendency of appeal – Adjustment of refunds for AYs 2021-22 and 2024-25 against demand for AY 2017-18 is bad in law when appeal for AY 2017-18 is pending; such demand ought to be stayed till disposal of the appeal. [S. 246A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Credits pertaining to earlier years-Transaction explained-Reassessment notice and order disposing the objection was quashed. [S. 68, 147, 148, 148A(b), 148A(d), Art. 226]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Income tax refund-Interest on excess payment of tax-Income derived from eligible business-Eligible for deduction- No substantial question of law. [S. 260A]

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. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Deduction-Rectification application of revenue was dismissed. [S. 80P(2)(d)]

S. 151 : Reassessment – Sanction for issue of notice –Order passed by ignoring revised return filed by assessee – No satisfaction recorded by Pr. CIT before granting approval- Reassessment order was quashed and set aside. [ S. 147 , 148 ]

S. 80P : Co-operative societies-Commission income from MSEDCL Bill Collection-Services rendered to members-Entitle to exemption. [S. 80P(2)(c)]

S. 68 : Cash credits-Capital is recorded through proper banking channel-Capital introduced by partner in firm-No addition can be made in the hands of the firm. [S. 2(31)(iv), 133(6)]

S. 68: Cash credits- Conversion of private limited company into LLP – The transfer of share capital and reserves to partners’ accounts upon conversion – The addition was not justified since the nature and source of the credit were explained and not unexplained. [S. 47(xiiib)(f), 115BBE]

S. 68 : Cash credits-Firm -Partners-Once partners’ identity, creditworthiness, and genuineness of capital contribution are established through evidence, addition u/s. 68 cannot be made in the firm’s hands, as the firm is not required to explain the source of partners’ funds. [S. 2(31)(iv)]