S. 68 : Cash credits-Accommodation entries-Information from Investigation Wing-Bhanwarlal Jain-Rajendra Jain-Gautam Jain group-No evidence that amount was credited-Addition is deleted.

S. 57 : Income from other sources-Deductions-Interest expenditure is more than interest income-Allowable as deduction. [S. 56, 57(iii)]

S. 56 : Income from other sources-Transfer-Conversion of tenancy right to ownership rights-Not taxable-No immoveable property is received-No addition can be made either in the hands of the assessee or the land lord. [S. 2(47), 56(2)(x)(b)]

S. 45 : Capital gains-Transfer of land owned by partnership firm to its partners-Transferred at cost by book entry-Adjusted against capital balance of partner-Not taxable as capital gains. [S. 2(47)]

S. 43(5) : Speculative transaction-Forward exchange contract-Loss on cancellation is held to be non speculative in nature.

S. 40A(2) : Expenses or payments not deductible-Excessive or unreasonable-Salaries paid to director cannot be disallowed on the ground that salaries paid in earlier year was less than the relevant year-Burden is on revenue to demonstrate that the remuneration is excessive as per market rate-Disallowance is deleted.

S. 37(1) : Business expenditure-Non-Compete fees paid to retiring partner-Allowable as revenue expenditure.

S. 37(1) : Business expenditure-Capital or revenue-Project cost-Pending capitalisation-Written off-Allowable as revenue expenditure.

S. 14A : Disallowance of expenditure-Exempt income-Amendment to section 14A by inserting explanation (Amended vide Finance Act, 2022) is applicable prospectively from AY. 2022-23 and not applicable to AY. 2013-14. [R. 8D]

S. 12A : Registration-Trust or institution-Lease transactions-Business income-Lease agreement for 50 Years-Violation of Maharashtra Stamp Act, 1958 and Maharashtra Public Trust Act, 1950-Denial of registration is affirmed. [S.12AA(1), Maharashtra Public Trust Act, 1950, S. 36(IA), Maharashtra Stamp Act, 1958, Registration Act, 1908, S. 17]