S.37(1): Business expenditure – Upfront fees and brokerage fees – Non -convertible debentures – Year of allowability – If the tax rate is uniform in two years then, the deduction whether claimed by the assessee in the year one or two is of no consequence to the revenue- The revenue expenditure is to be allowed in the year in which it is incurred but it could be spread over only at the instance of an assessee – Order of Tribunal is affirmed – No substantial question of law .[ S. 145 , 260A ]

S .14A : Disallowance of expenditure – Exempt income – Disallowance under Section14A cannot exceed the exempt income – No substantial question of law.[ S.260A ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice Principle of Natural Justice – Non-Application of Mind by Authorities- Role of Principal Commissioner of Income Tax (PCIT) – Approval under Section 151- Strictures -Interplay Between CGST Act and Income Tax Act- Costs and Accountability of Tax Authorities- The High Court held that the reopening of assessment under Section 148 was invalid as it was based on mechanical approval and a lack of due diligence by the tax authorities- Imposed personal costs of ₹25,000 each on the Assessing Officer and the Principal Commissioner of Income Tax, payable to the National Association for the Blind, Mumbai for arbitrary and unjustified actions serves as a deterrent against abuse of authority and reinforces accountability in the exercise of statutory powers- Directed the Ministry to scrutinize the conduct of the involved officers for accountability. [S. 148 , 148A(b) 148A(d), 151 , Art. 226 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice Principle of Natural Justice – Non-Application of Mind by Authorities- Role of Principal Commissioner of Income Tax (PCIT) – Approval under Section 151- Strictures -Interplay Between CGST Act and Income Tax Act- Costs and Accountability of Tax Authorities- The High Court held that the reopening of assessment under Section 148 was invalid as it was based on mechanical approval and a lack of due diligence by the tax authorities- Imposed personal costs of ₹25,000 each on the Assessing Officer and the Principal Commissioner of Income Tax, payable to the National Association for the Blind, Mumbai for arbitrary and unjustified actions serves as a deterrent against abuse of authority and reinforces accountability in the exercise of statutory powers- Directed the Ministry to scrutinize the conduct of the involved officers for accountability. [S. 148 , 148A(b) 148A(d), 151 , Art. 226 ]

S. 271(1)(c) : Penalty – Concealment -Additional legal ground is admitted -Not specifying the charge – Levy of penalty is not valid – Substantial question of law is admitted before High Court – Penalty cannot be levied- The decision in Veena Estate P.Ltd v. CIT( 2024) 464 ITR 483 ( Bom)( HC) is distinguished . [ S. 68, 69, 260A, 274 ]

S. 32: Depreciation – Car registered in name of director – Funds utilized of the company – Depreciation is allowable to the company.

S. 272A : Penalty – Failure to answer questions – Sign statements – Furnish information – Substantial compliance – Levy of penalty is not justified. [S. 143(3), 272A(1)(d)]

S. 271(1)(c) : Penalty – Concealment – Bogus purchases – Estimated addition – Levy of penalty is not valid.[S.69A]

S. 263: Commissioner – Revision of orders prejudicial to revenue – Assessment order passed after making necessary inquiries – Held, revision proceedings cannot be initiated simply because PCIT was of the opinion that further inquiries should have been made on the issue.[ S.143(3) ]

S. 251 : Appeal – Commissioner (Appeals) – Powers – Appeal cannot be dismissed on account of non-prosecution- Order is set aside and directed to decide on merits. [S. 246A, 251(2)]