S.11: Property held for charitable purposes -Accumulation of income — Allowable at fifteen per cent. on gross receipts

S. 2(22)(e):Deemed dividend- account showing movement of funds both ways between a debtor and a creditor – Held, current account transaction and therefore, S. 2(22)(e) would not apply.

S. 271AAA : Penalty – Search initiated on or after 1st June, 2007 – Levy of penalty at the rate of 10% of the undisclosed income to be imposed only in respect of ‘specified previous year’ – The CIT(A) restricted penalty without examining ‘Specified Previous Year’, matter was set aside to AO for fresh consideration in light of explanation(b) S.271AAA.

S.271AAA : Penalty – Search initiated on or after 1st June, 2007 – Assessee has to specify and substantiate manner of income, has been derived in its statement recorded u/s. 132(4) and not thereafter- Levy of penalty is justified . [ S.132(4) ]

S.271AAA : Penalty – Search initiated on or after 1st June, 2007 – Assessee has to specify and substantiate manner of income, has been derived in its statement recorded u/s. 132(4) and not thereafter- Levy of penalty is justified . [ S.132(4) ]

S. 271(1)(c) : Penalty – Concealment – Notice issued without striking out irrelevant words – shows non application of mind – Penalty not sustainable.

S. 271(1)(c) : Penalty – Concealment- The AO did not specify under which limb had the penalty been imposed i.e whether it was on account of concealment of income or for furnishing of inaccurate particulars of income, then penalty was not sustainable. [ S.274]

S. 271(1)(c):Penalty- Concealment -Penalty cannot be levied on AO’s invocation of wrong limb while recording satisfaction

S. 271(1)(c): Penalty –Concealment – When penalty notice did not specify which limb of S. 271(1)(c) penalty proceedings had been initiated i.e. whether for concealment of particulars of income or furnishing of inaccurate particulars, Penalty should be deleted.

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
– Capital gains – Investment in construction of another house property within prescribed time – Deduction cannot be denied merely because exemption was not claimed in return of income. [ S. 45,54F, 139 ]