S. 69C : Unexplained expenditure-Bogus purchases-Books of account not rejected-Tribunal restricting the income at 6% of bogus purchases-No substantial question of law. [S. 260A]

S. 37(1) : Business expenditure-Corporate social responsibility expenditure-Expenditure for earlier years allowable as a deduction-CBDT Circular binding on the department.

S. 32 : Depreciation-Goodwill, Patent, Trade Mark and Intellectual Property Rights-Intangible assets-Entitled to depreciation-Trademark need not be registered in assessee’s name. [S. 32(1(ii)]

S. 10(26AAAA): Income of Sikkimese – Individual- Old Indian settlers who had settled in Sikkim prior to the merger of Sikkim with India on April 26, 1975 were also entitled to the exemption-Proviso excludes from the provision of exemption a Sikkimese woman merely because she marries a non-Sikkimese after April 1, 2008 is discriminatory and violative of articles – Law declared by Court to be treated as law until legislation is made. [ Sikkim Income Tax Manual, 1948, Sikkim Citizenship (Amendment) Order, 1989 — Sikkim Work Permit Rules, 1965, Art. 14 15 142 371F ]

Direct Tax Vivad Se Vishwas Act, 2020 .

S. 4: Declaration – Delay in payment of tax Time limit for deposit of tax — Substantial amount was deposited – Failure of the Chartered Accountant to information from the portal -Directed the Revenue to accept the balance deposit of tax with interest [ S. 119(2)(b), Art , 226 ]

S. 276CC : Offences and prosecutions-Failure to furnish return of income-Levy of penalty-Tribunal set aside the penalty order-Prosecution is not justified. [S. 271(1)(c), 271F, 276C]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Not all information in possession of the officer can be construed as information that qualifies for initiation of proceedings for reassessment, and it is only such information that suggests escapement and which, based upon the material in his possession-Agreement between doctors and hospital-remuneration paid for fixed amount along with components such as number of patients treated etc. [r.w.s.15, 17, 28(i)][S. 148, Art. 226]

S. 148A : Reassessment Notice-show cause notice before passing the order-Petitioner within a period of four days submitted reply-the petitioner cannot challenge the notice on the ground that clear seven days’ time was not afforded-Writ petition was dismissed. [S. 148, Art, 226]