S. 115WB : Fringe benefits-Limitation –Additional grounds-Notice issue under section 143(2) after six months from the end of relevant financial year-Notice is invalid-Tribunal is justified in admitting additional grounds. [S. 115WE(2), 143(2), 254(1)]

S. 69A : Unexplained money-Assessment against yard owners was completed-Addition of same income in the hands of the petitioner was directed to be deleted-Matter remanded. [S. 153C, Art. 226]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Commission, brokerage, etc.-Passenger service fees (PSF)-Not liable to deduct tax at source-Matter remanded for verification. [S. 194H]

S. 36(1)(viii) : Eligible business-Special reserve-Agricultural development-Eligible business-Dairy or animal husbandry activities-Providing long term finance to various dairy co-operatives engaged in producing milk-Not eligible to claim deduction.

S. 36(1)(v) : Contribution to approved gratuity fund-Gratuity trust-Deed of variation pending for approval-Not allowable as deduction.[S. 43B]

S. 14A : Disallowance of expenditure-Exempt income-No exempt income-No disallowance can be made [R. 8D]

S. 56 : Income from other sources – Relative – Individual – Private discretionary trust – Gift of equity shares to trust – Trust crested for the benefit of self and relatives – Any sum received without consideration , aggregate value of which exceeds fifty thousand rupees – Pass through entity – Provision of section 56(2)(x) is not applicable [ S. 56(2)(x)) ] S. 56 : Income from other sources – Relative – Individual – Private discretionary trust – Gift of equity shares to trust – Trust crested for the benefit of self and relatives – Any sum received without consideration , aggregate value of which exceeds fifty thousand rupees – Pass through entity – Provision of section 56(2)(x) is not applicable [ S. 56(2)(x)) ]

S. 148A: Reassessment – Limitation – Notices issued pursuant to the case of UOI v. Ashish Agarwal (2022) 444 ITR 1/ 213 DTR 217/ 326 CTR 473/ 286 Taxman / AIR 2022 SC 2781 (SC) – Notice issued on or after 01.04.2021, the period concerned is between 01.04.2021 to 30.06.2021-Relaxation Act will not apply – The law as per Finance Act, 2021 has to be followed- Notice issued for Assessment years 2013 -14 and 2014 -15 are barred by limitation – The submission that the UOI v. Ashish Agarwal (Supra) would be applicable to the cases, where such notices have been challenged before different High Courts only, were not accepted. [S. 119, 147, 148, 148A(d), 149, 151, 151A, Taxation and Other Laws (Relaxation & Amendment of Certain Provisions) Act, 2020, S. 3(1), CBDT Instruction, 31-3-2021, Art. 226]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before the issue of notice – Limitation – Notices issued pursuant to the case of UOI v. Ashish Agarwal (2022) 444 ITR 1/ 213 DTR 217/ 326 CTR 473/ 286 Taxman / AIR 2022 SC 2781 (SC) – Notice issued on or after 01.04.2021, the period concerned is between 01.04.2021 to 30.06.2021-Relaxation Act will not apply – the law as per Finance Act, 2021 has to be followed.-CBDT Instructions No.1 of 2022 (2022) 444 ITR 43 ( St)- Interpretation Of Taxing Statutes — Strict Interpretation. [S. 119, 147, 148, 148A(d), 149, 151, 151A, Taxation and Other Laws (Relaxation & Amendment of Certain Provisions) Act, 2020, S. 3(1), CBDT Notification, 31-3-2021, Art. 226]

S. 260A : Appeal-High Court-Finding of fact-High Court must frame the substantial question of law-Order setting aside the order of Tribunal was quashed and set aside-Order of Tribunal was affirmed. [Interest-tax Act, 1974, S. 2(5A), 2(5B), 2(7)]