S. 35DDA : Amortisation of expenditure-Voluntary retirement scheme-Accrued liability-Allowable as deduction [S. 43(2), 145]

S. 32 : Depreciation-Claim of depreciation as permissible-Deletion of disallowance was proper.

S.14A : Disallowance of expenditure-Exempt income-Only expenses proportionate to earning of exempt income could be disallowed [R. 8D]

S.14A : Disallowance of expenditure-Exempt income-Failure to record satisfaction-Invoking rule 8D is not justified-Disallowance proposed by the assessee is affirmed [R. 8D]

S. 12AA : Procedure for registration-Trust or institution-Educational institution-Failure to file return-Matter was remanded back to file of Commissioner (E) with direction to grant registration under section 12A if objectives and activities of assessee were found to be same-Order of Tribunal affirmed [S. 12A]

S. 12AA : Procedure for registration-Trust or institution-Cancellation of registration is not valid on the ground which was not contained in show cause notice [S. 115BBC]

S. 10B: Export oriented undertakings-Agreement with Central Government-Ministry of Commerce granting hundred percent export oriented unit-Entitle to exemption-Exemption cannot be denied merely on the ground that the assessee has not claimed exemption in return of income. [S. 10A, 139, Industrial (Development & Regulation) Act, 1951 S. 14]

S. 10 (23C): Educational institution-Medical university-Statement of accountant of a promotor/sponsor-Books of account-Refusal of registration and approval under section 80G is held to be not valid. [S. 10(23)(vi), 12AA, 80G (5)(vi)]

S. 36(1)(vii): Bad Debts – Business loss- Amount paid to builder towards acquisition of commercial premises – Write off of the amount as irrecoverable neither allowable as bad debt nor as business loss – Assessee to prove both conditions of section 36(1)(vii) and 36(2) of the Act are satisfied- [S. 28(i) 36(2), 37 (1) ]

S. 268A : Appeal – Application –Reference – Instructions – Monetary Limits- Exceptions —Circular No. 23 of 2019 providing that monetary limits would not apply where CBDT by special order directed filing of appeals — The legislative intent is clear that circular dated September 6, 2019 would not apply with retrospective effect-Though the Revenue had alleged organized tax evasion activity on the part of the assessee in those pending appeals as on the date of Circular No. 23 of 2019, the Revenue could not be allowed to pursue these appeals. Since the tax effect involved in this batch of appeals was less than the monetary limit prescribed in the earlier circulars of the Central Board of Direct Taxes -, The Revenue was not allowed to proceed the appeals on the merits – Appeals of the revenue was dismissed .[ S. 119, 260A ]