S. 148: Reassessment – Limitation – Notice issued under section 148 after expiry of six years under the erstwhile law is barred by limitation notwithstanding that notice under section 148A(b) was issued within the limitation period – Reassessment quashed. [S. 147, 148A(b) 149]

S. 69A: Unexplained money – Alleged on-money paid for purchase of flat – Principles of Natural Justice – Addition based solely on statement of builder and uncorroborated Excel sheets seized during search – No incriminating material supplied to assessee – Cross-examination denied – Addition deleted. [S. 132(4), 147, 148, 254(1), Evidence Act, 1872, S. 65B ]

S. 80G: Donation-Deduction – Corporate Social Responsibility (CSR) expenditure – Donation made as part of CSR obligation to an institution approved under section 80G is eligible for deduction – Disallowance under Explanation 2 to section 37(1) does not bar deduction under Chapter VI-A. [ S . 37(1), Companies Act, 2013, S. 135]

S. 147: Reassessment – Supply of reasons –Accommodation entries – Furnishing only the gist of the reasons instead of the complete recorded reasons vitiates the reassessment proceedings. Reassessment based solely on a statement which had already been retracted and whose retraction had been accepted by the appellate authority does not constitute a valid “reason to believe” that income had escaped assessment. [S. 143(3), 148 ]

S.37(1): Business expenditure – Builder – Payments to tenants /occupants – Compensation payable for vacating the occupants – Mercantile system of accounting – Provision for liability towards payment to occupants/tenants – Accrued liability allowable – Mere deferment of quantification or payment does not render liability contingent. [S 28, 145, Accounting Standard-29 ]

S. 69: Unexplained investments – Foreign assets – Foreign investments were jointly held with the assessee’s husband, acquired through disclosed remittances in earlier years under the Liberalised Remittance Scheme (LRS), and supported by contemporaneous documentary evidence including bank statements, PMS reports, reconciliation statements, balance sheets and Schedule FA disclosures of both co-holders-No addition under section 69 could be made by treating the husband’s share of investment as unexplained investment in the hands of the assessee merely on suspicion and without any contrary evidence- Addition towards unexplained foreign investment deleted. [S. 143(3), 144B, Schedule FA]

S. 271DA: Penalty for failure to comply with provisions of section 269ST-Sale consideration over 2 lakhs-Genuineness of transaction was not doubted-Sales to farmers-technical and venial breach-AO is directed to delete the penalty. [S. 269ST, 274]

S.271D: Penalty-Takes or accepts any loan or deposit-Agent-An agent in a transaction of transfer of immovable property between a buyer and seller, cannot be held liable for penal consequence under section 269SS for receiving, for and on behalf of and handing over money to his principal-Not liable for penalty.[S. 269SS, 273B, Indian Contract Act, 1872, S. 226]

S. 271(1)(c): Penalty-Concealment-Disclosure of income in the course of survey-Prior to due date of filing of return-Income returned was accepted-Levy of penalty was deleted. [S.133A, 139(1)]

S. 271(1)(c): Penalty-Concealment-Failure to file return-Addition on estimate basis-Levy of penalty is held to be justified, though the addition was made on an estimate basis applying the explanation 3 [S. 139, 148]