S. 37(1): Business expenditure-Infrastructure fee-Advertising receipts-Tribunal was justified in restricting deduction to 5 per cent of actual receipts in accordance with the agreement and not on the gross advertising bill-Order of Tribunal affirmed. [S.145, 260A]

S. 37(1): Business expenditure-Broken period interest-Securities held as stock-in-trade-Deduction allowable.[S.145, 260A]

S. 37(1): Business expenditure-Personal element-Disallowance-Pure finding of fact-Commission payment-Services not established-Finding of fact-No substantial question of law.[S.260A]

S. 37(1) : Business expenditure-Client assistant charges-Three-in-one account scheme-Expenditure incurred for business allowable-Provision for loss-Contingent liability-Conservative principle-Deduction allowable [S. 145, 260A]

S. 36(1)(vii) : Bad debt-Advances-Business loss-Write-off of unrecovered advances-Genuineness not disputed-Deduction allowable. [S,28(i), 260A]

S.14A: Disallowance of expenditure-Exempt income-Interest-free funds-Non-interest-bearing funds were more than the investment made in tax-free securities; it would be presumed that the investment made by the assessee would be from its interest-free funds and, thus, no disallowance under section 14A could be made-Order of Tribunal affirmed. [S.260A, Rule 8D]

S. 10A: Free trade zone-STP Unit-New infrastructure, plant and machinery, software and separately recruited workforce-Undertaking not formed by splitting up or reconstruction of existing business-Deduction allowable-Order of Tribunal affirmed. [S. 10A(2), 260A]

Direct Tax Vivad Se Viswas Act, 2024.
S 91 : Filing of declaration and particulars to be furnished-Prior tax position revived when assessee does not comply with provisions / requirements of DTVSV Act 2020 and hence eligible under DTVSV Act 2024.[DTVSV Act, 2020, S. 4(6), 5(1)Art. 226]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-When the subject matter of the penalty, which was the very basis on which criminal proceedings had been launched, was set aside, criminal proceedings could not be allowed to continue.[S.271(1)(c), 277]

S. 276B : Offences and prosecutions-Failure to pay to the credit tax deducted at source-Revenue had accepted statutory compounding fee under section 279 in relation to alleged offences under sections 276B and 278B-Continuation of criminal proceedings after such compounding constituted abuse of process and liable to be quashed. [S. 278B, 279, Art.21, 226]