S. 31 : Repairs-Current repairs-Capital or revenue-Treated capital in nature in books-Allowable as deduction-Matter is remanded to the Assessing Officer. [S. 37(1), 145]

S. 28(iv) : Business income-Value of any benefit or perquisites-Converted in to money or not-Capital Gains-Loss-Conversion of loan given to subsidiary to optionally convertible preference shares at face value-Merchant Banker’s valuation report-Not tax avoidance-Cost of acquisition tenable.[S. 41(1)]

S. 28(i) : Business income-Income from other sources-Leasing and finance-Interest-Non-Banking finance-Rule of consistency-Assessable as business income.[S. 56]

S.14A : Disallowance of expenditure-Exempt income-Disallowance cannot exceed amount of exempt Income. [S.10(34) R.8D]

S.14A : Disallowance of expenditure-Exempt income-Book profit-No disallowance can be made-Amendment disallowance of expenditure irrespective of receipt of exempt income-Not Retrospective-Order of CIT(A) is affirmed. [S.115JB, R.8D]

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

S. 14A : Disallowance of expenditure-Exempt income-Investment in subsidiaries not yielding dividends-Own interest-free funds-No disallowance of expenditure. [R.8D]

S. 12AB: Procedure for fresh registration-Cancellation of registration-Order of cancellation of registration is quashed-Document Identification Number-Order in CIT v. Brandix Mauritius Holdings Ltd (2024)158 taxmann.com 247 (SC) is suspended till issue decided by Supreme Court. [S. 12A, 12AA, 12AB(4)]

S. 12AA : Procedure for registration-Trust or institution-cancellation of registration-New Section brought with effect from 1-4-2022 providing for reference by Assessing Officer to Principal Commissioner or Commissioner proposing withdrawal of registration in case of Specified violation by trust or institution-Amendment is prospective-Law inserted with effect from 1-4-2022 would not apply retrospectively-Cancellation of registration is bad in law and registration is to be restored. [S.2(15), 11, 12AB(4) 13(2(a) 13(2)(g) 13(3)]

S. 11 : Property held for charitable purposes-Promote welfare and causes of craftsmen-Ex-parte order by CIT(A)-Issue is set aside to Assessing Officer for de novo assessment as per ratio in ACIT v. Ahmedabad Urban Development Authority(2022) 449 ITR 1 (SC) [S. 2(15), 12A]