S. 40A(2) : Expenses or payments not deductible-Excessive or unreasonable-Salaries paid to director cannot be disallowed on the ground that salaries paid in earlier year was less than the relevant year-Burden is on revenue to demonstrate that the remuneration is excessive as per market rate-Disallowance is deleted.

S. 37(1) : Business expenditure-Non-Compete fees paid to retiring partner-Allowable as revenue expenditure.

S. 37(1) : Business expenditure-Capital or revenue-Project cost-Pending capitalisation-Written off-Allowable as revenue expenditure.

S. 14A : Disallowance of expenditure-Exempt income-Amendment to section 14A by inserting explanation (Amended vide Finance Act, 2022) is applicable prospectively from AY. 2022-23 and not applicable to AY. 2013-14. [R. 8D]

S. 12A : Registration-Trust or institution-Lease transactions-Business income-Lease agreement for 50 Years-Violation of Maharashtra Stamp Act, 1958 and Maharashtra Public Trust Act, 1950-Denial of registration is affirmed. [S.12AA(1), Maharashtra Public Trust Act, 1950, S. 36(IA), Maharashtra Stamp Act, 1958, Registration Act, 1908, S. 17]

S. 2(31) : Person-Association of person-Characterization of consortium-Agreement-Terms of the agreement will be the deciding factors-Taxable as an AOP and not as individual members.

S. 68 : Cash credits – Cash deposit – Demoetizaation- Sales – Produced names , address , PAN etc- Parties have responded to the notices u/s 133(6)- Sales are accepted by VAT department – No defects in the books of account – Order of CIT(A) deleting the addition is affirmed .[ S.133(6), 143(3) ]

Direct Tax Vivad Se Vishwas Scheme, 2024 (2024) 467 ITR 1 (St)(63)
S. 89 : Definitions-Appellant-Benefit of Vivad Se Vishwas Scheme, 2024 extended to those assesses in whose case the time for filing appeal has not expired as on 22 July 2024.[S.89(1)(a)) DTVSV Act, 2020, S. 2(1)(a), Art. 226]

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015.

S. 51: Punishment for willful attempt to evade tax-Failure to file return-Search-Prosecution not dependent on completion of assessment-Summing order is upheld-Alternative remedy-Writ petition is dismissed, [S.2(12), 16, 50, 51, Income-Tax Act 1961, S. 131(IA), 132, 139]

S. 281 : Certain transfers to be void-Writ-Recovery of tax-Attachment of property-Transfer of property-Validity-Assessee denying sale of attached property to petitioner-Transfer void ab initio-Tax Recovery Officer not required to declare sale as invalid-Petitioner given liberty to file Civil suit in Civil Court. [S. 220(6),, Sch II R.11 Art. 226]