S. 14A : Disallowance of expenditure – Exempt income – Recording of satisfaction- Mixed funds – Maxopp Investment Ltd. v. CIT (2018) 402 ITR 640 (SC) does not lay down a proposition that the moment it is demonstrated that the assessee had availed of mixed funds, i. e., interest-free as well as interest bearing funds and utilized them for making investments into securities earning tax-free income and the rest applicability of section 14A read with rule 8D would be automatic Resorting to the method prescribed under rule 8D is not automatic-Deletion of addition by the Tribunal is held to be justified. [R. 8D]

S. 14A : Disallowance of expenditure-Exempt income – Mixed funds-Having sufficient own funds–No disallowance can be made. [R. 8D]

S. 264 : Commissioner-Revision of other orders–Appeal filed was withdrawn–Revision application is maintainable-Writ petition is maintainable against the revision order -Sale of agricultural land-In the assessment of Co-owner the land was accepted as agricultural land–Rejection of revision application was held to be not valid–Matter remanded. [S. 45, 264(4)(a)]

S. 254(1) : Appellate Tribunal – Duties- Reassessment —Tribunal reversing decision of Commissioner (Appeals) without cogent reasons — Order of Tribunal is held to be not valid. [S. 147]

S. 254(1) : Appellate Tribunal–Duties-Reversal of findings of fact of Assessing Officer by Tribunal without recording reasons and also not deciding the cross appeal filed by the department- Matter remanded to Tribunal for fresh adjudication. [S. 80IB]

S. 195 : Deduction at source-Non-resident-Payment for technical services rendered outside India–Amendment with retrospective effect from 1-4-1962- Not liable to deduct tax at source. [S.9(1)(1) (vii)]

S. 147 : Reassessment—Notice issued based on overruled judgment is illegal and improper. [S. 43D, 148]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts- Reassessment is bad in law. [S. 148]

S. 92C : Transfer pricing–Arm’s length price–Comparable- Working capital adjustment–Question of fact–No substantial question of law. [S. 260A]

S. 68 : Cash credits—Credit entries in bank account is not explained satisfactorily–Genuineness of transaction is not proved -Order of Tribunal confirming the addition is held to be justified. [S. 69A]