S. 12A : Registration-Trust or institution-Procedure for fresh registration-Failure to reply show cause notice-Matter remanded back to Commissioner (Exemption) with a direction to grant one final opportunity to assessee to substantiate its case by filing requisite details. [S.12AB]

S. 10AA : Special Economic Zones-Transfer pricing adjustment-Eligible for deduction under section 10AA in respect of voluntary adjustment made by it-Transfer Pricing adjustment made by it [S.92C]

S. 10(23G) : Infrastructure undertaking-Banking company-Made investments or had advanced loans to companies engaged in business of infrastructure development-Eligible for claiming exemption.

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Amount received by assessee from Indian customers on account of sale of software solutions could not be treated as royalty-DTAA-India-USA. [Art. 12]

S. 5 : Scope of total income-Non-resident employee of an Indian company-Income from employment-Foreign assignment allowances for services rendered in Indonesia-Services were rendered outside India-Allowances were not taxable in India-DTAA-India-Indonesia [S. 5(2)(b), 9(1)(i), Art. 15]

S:68: Cash credits – Unexplained Credit – Conversion of Company to LLP – Capital Account – Accumulated Profits –Capital gains – Mere accounting entry, without actual monetary benefit to the partners, does not constitute payment for alleged Violation of Section 47(xiiib)(f) – Book Entry – No Actual Payment – Burden on AO – Addition is deleted .[ S.45 , 47(xxib)(f), 115BBE , Limited Liability Partnership Act , 2008 , S. 56, 57 ]

S. 69A: Unexplained Investments – Unexplained Money – Demonetization- –Deposit of cash – Business receipts – Recorded in Books –Acceptance of Specified Bank Notes ( SBNs) prior to 31.12.2016 is not illegal – Addition is deleted.

S. 153A: Assessment – Search – Alleged transfer of Development rights – Reassessment based on seized ledger account and third-party statement – No independent inquiry conducted by the AO – No evidence to link the assessee to the transaction – Addition is deleted . [S. 131, 147, 148, 153A, 153C]

S.148: Reassessment – Notice – Issued notice without disposing of assessee’s objections – Breach of principle of natural justice – Reassessment order was quashed .[S. 147, 153A ]

Direct Tax Vivad Se Vishwas Scheme, 2024
S.2(1)(a): Appellant-time for filing appeal has not expired-[S.91, Art. 226]