S. 2(31) : Person-Association of person-Characterization of consortium-Agreement-Terms of the agreement will be the deciding factors-Taxable as an AOP and not as individual members.

S. 68 : Cash credits – Cash deposit – Demoetizaation- Sales – Produced names , address , PAN etc- Parties have responded to the notices u/s 133(6)- Sales are accepted by VAT department – No defects in the books of account – Order of CIT(A) deleting the addition is affirmed .[ S.133(6), 143(3) ]

Direct Tax Vivad Se Vishwas Scheme, 2024 (2024) 467 ITR 1 (St)(63)
S. 89 : Definitions-Appellant-Benefit of Vivad Se Vishwas Scheme, 2024 extended to those assesses in whose case the time for filing appeal has not expired as on 22 July 2024.[S.89(1)(a)) DTVSV Act, 2020, S. 2(1)(a), Art. 226]

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015.

S. 51: Punishment for willful attempt to evade tax-Failure to file return-Search-Prosecution not dependent on completion of assessment-Summing order is upheld-Alternative remedy-Writ petition is dismissed, [S.2(12), 16, 50, 51, Income-Tax Act 1961, S. 131(IA), 132, 139]

S. 281 : Certain transfers to be void-Writ-Recovery of tax-Attachment of property-Transfer of property-Validity-Assessee denying sale of attached property to petitioner-Transfer void ab initio-Tax Recovery Officer not required to declare sale as invalid-Petitioner given liberty to file Civil suit in Civil Court. [S. 220(6),, Sch II R.11 Art. 226]

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Compounding of offence-Compounding application could not have been rejected on delay alone-Limitation-CBDT guidelines dated 16 November 2022.[S. 279(2), Art.226]

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Certain categories of offences not to be compounded other than first offence-Wilful failure to file returns in due time-“First offence” as defined in Guidelines-Failure to file return before due date for assessment year 2013-2014 despite issue of notice for not filing in time for assessment year 2011-2012-Offence committed by assessee not first offence-Rejection of application in consonance with Guidelines; Guidelines for Compounding of Offences under Direct Tax Laws, 2008 (2015) 371 ITR 7 (St). [S. 139, 276CC279(2), Art. 226]

S. 276: Offences and prosecutions-Wilful attempt to evade tax-Delay in payment of tax does not amount to evasion of tax-Prosecution is not valid.[S. 276(2)]

S. 275: : Penalty-Bar of limitation-Failure to deduct tax at source-Survey-Notice for penalty after five years-The penalty order is barred by limitation if issued after the statutory time frame of six months from the end of the month in which penalty proceedings were initiated-Notice and penalty is unsustainable. [S. 260A, 271C, 272A(2)(c) (k), 275(1)(c)]