S. 147 : Reassessment – Bad debt – Involved mixed questions of fact and law as to validity of reopening and taxability of amount received under debt waiver scheme, the High Court was not a proper forum to decide such mixed question and matter was to be remanded back to AO.[ S. 36(1)(viia), 254(1), 260A]

S. 115JB : Provisions of section 11JB will not apply to the taxpayer being a corporation established under Damodar Valley Corporation Act, 1948.[ Damodar Valley Corporation Act, 1948 ]

S.115BAA : Tax on income of certain domestic companies – Omission to file Form No 10IC – Directed to file an appropriate application in writing addressed to the Principal Chief Commissioner / Chief Commissioner making a request to permit it to file the Form 10IC electronically after condoning the delay in that regard so that the return of the Assessee can be re-processed or regular assessment can also be framed accordingly. [ S.115BA, 115BAB, 119(2)(b), Form No 10IC , Art , 226 ]

S. 68 : Cash credits – Credit balance of the associate parties – Purchase transactions- Identity , creditworthiness and genuineness of the transactions of purchases made is proved – Deletion of addition is affirmed – No substantial question of law .[ S. 260A ]

S. 11 : Property held for charitable purposes – Corpus donation – When the Assessee-trust has received donations for specific purposes with specific directions by donors alongwith signatures of such donors, then such receipts are to be treated towards corpus donations. [ S. 12 ]

S. 254(2A): Appellate Tribunal –Stay- ITAT has power to grant stay only if the asseessee pays 20 % of the tax in dispute or furnishes equal amount of security of like amount [ S. 220(6) , 253, 254(1)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Claim of set off of non speculative business loss against the profit of speculated business-Revision order is quashed. [passed by the PCIT u/s. 263 of the Act is quashed. [S. 28 (i), 72, 73]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-When valid and lawful agreement is entered by the parties prior to 1 April 2014 but the property was registered after said date, provisions of the amended section 56(2)(vii)(b) would be inoperative and therefore an assessment order passed after due consideration of all facts but without invoking the provisions of the amended section 56(2)(vii)(b) cannot be said to be erroneous and prejudicial to the interest of the revenue.

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Bogus accommodation entries-Revision on the basis of roving enquiries-CBDT circular on no set-off of loss against deemed income u/s 115BBE applicable w.e.f. 1st April 2017-Invocation of section 263 jurisdiction by the Ld. CIT is invalid-Income assessed remains same even pursuant to revision-Revision is not valid. [S. 56, 68, 115BBE, 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to Revenue-AO failure to verify the genuineness of the lenders-Complete details not submitted by the assessee-Revision justified. [S. 133(6), 143(3), 147, 148]