S. 40A(2) : Expenses or payments not deductible-Excessive or unreasonable-Consultancy charges paid to related party-No comparable instances cited by AO-Disallowance is deleted. [S. 40A(2)(b)]

S. 11 : Property held for charitable purposes – Excess expenditure over income-Accumulation of income-Applied charitable purpose – Denial of exemption is not valid. [S. 11(1)(a), 12A]

S. 11 : Property held for charitable purposes – Accumulation of income-Amendment by Finance Act, 2022, restricting accumulation applies prospectively from 1-4-2022- Trust could validly utilize accumulated income of earlier years up to 31-3-2023 within original time window. [S. 11(3)(c)]

S. 4 : Charge of income-tax – Capital or revenue – Compensation received for under performance of wind turbine generators (WTGs)- Capital receipt. [S.28(i)]

S. 151A: Face less assessment scheme – Reassessment – Faceless jurisdiction – Manual DIN – Reassessment held void ab initio – Jurisdictional AO issued notice instead of Faceless AO – Assessment order manually issued without computer-generated DIN – Proceedings invalid. S. 147, 148 151, CBDT Circular No. 19/2019 ]

S. 69A : Unexplained money – Rough diary notings – Internal circulation of funds –Statement in the Course of search – Statement retracted – Addition unsustainable.[ S. 132, 132(4), 132(4A) ]

S. 45 : Capital gains – Alleged NOC receipts – Loose sheets – Statement in the Course of search – Statement retracted – No corroboration – Additions deleted. [ S.132, 132(4), 132(4A) ]

Prohibition of Benami Property Transactions Act, 1988

S. 26(3) : Appeal-Order of adjudicating authority-Writ cannot be issued. [S.24, Art. 226]

Direct Tax Vivad Se Vishwas Scheme, 2024.
S. 2(i)(j): Disputed tax-Pendency of appeal-Non-resident-Authority for Advance Rulings holding taxable capital gains arose out of conversion of Indian subsidiary company to limited liability partnership-Pendency of writ-Capital gains from conversion of shares to interest in limited liability partnership brought to tax in reassessment proceedings-Not disclosing pending writ petition-Pendency of appeal before CIT(A)-Designated authority directed to process declaration considering date of original declaration and issue appropriate certificate. [S. 245Q(1), 245R(4), 250 Art.226]

Direct Tax Vivad se Vishwas Act, 2020.

S. 2(i)(j): Disputed tax-Pendency of appeal-Binding circular-Review pending before Supreme Court on specified date-Review petition was dismissed-Rejection application was set aside-Interpretation of taxing statutes Beneficial legislation requires purposive construction. [S. 2(1)(a)(i), ITAct,1961, S.119, Art, 226]