S. 17(2): Salary-Perquisite-Valuation of shares-Face value-Shares allotted as part of employee stock purchase scheme Lock-in period during which shares could not be transferred-Valuation of shares taking into account restrictive condition. [ S. 17(2)(iiia), 260A]

S. 12A: Registration-Trust or institution-Cancellation of registration-Treating donation as corpus and later treating as general donation and paying tax as per order of Settlement Commission under section 245C-Cancellation of registration not valid.[ S. 12AA(3), 245C, 260A ]

S. 4 : Charge of income-tax-Capital or revenue receipt-Security deposits-High Court admitted appeal to decide whether Tribunal was justified in treating amount received as security deposit which was forfeited as a capital receipt. [S. 260A]

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. 69C : Unexplained expenditure – Bogus purchases -Information from sales tax department – Bogus accommodation entries – Purchases – Payments through banking channels – Sales accepted – Addition restricted to 5 percent – PCIT v. Kanak Impex (India) Ltd. [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) distinguished. [ S. 143(3) ]

S. 69C : Unexplained expenditure – Bogus purchases – Addition restricted to 4% – Tribunal held that since purchases were supported by invoices, bank statements, stock register, and no defect was found in books or sales, only profit element could be added. High Court decision in PCIT v. Kanak Impex (India) Ltd. [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) distinguished- Appeal of revenue was dismissed .

S. 69C : Unexplained expenditure – Bogus purchases – Addition made on estimated basis of 25% of purchases deleted – Purchases supported by bills, stock register, delivery challans and bank payments – Supplier appeared before AO and confirmed sales – ITAT held that once purchases are corroborated by evidence and vendor’s statement, no addition could be sustained – Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished . [ S. 68 ]

S. 69C : Unexplained Expenditure – Bogus Purchases – Addition unsustainable when purchases supported by documents, payments through banking channel, sales accepted, and no cross-examination allowed – VAT authorities accepted purchases-Addition was deleted -Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished .[ S.133(6), 144 ]

S. 69C : Unexplained expenditure -Bogus Purchases – Only profit element to be taxed- Addition restricted to 12.5% of alleged bogus purchases- Bombay High Court ruling in PCIT v . Kanak Impex(India ) Ltd [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) is distinguished . [ S. 133(6), 147 , 148 ]