S. 119 : Central Board of Direct Taxes-Return-Condonation of delay-Filed after six years-Directed to accept the return and the assessee is directed to rectify the errors and the claim for refund should be processed in accordance with law. [S. 119(2)(b), 139, 240, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Most appropriate method-TNMM-CUP-Most appropriate method-Order of the Tribunal is affirmed-No substantial question of law.[S. 260A]

S. 44B : Shipping business-Non-residents-Computation-Certificate issued by Singapore Tax authorities will constitute sufficient evidence for accepting the legal position-No substantial question of law-DTAA-India-Singapore. [S.90,260A, Art., 9, 8, 24(1)]

S. 13A : Political parties-Income of political parties-Electoral Bond-Constitutional validity-Right to information of the voter includes the right to information of financial contributions to a political party because of the influence of money in electoral politics (through electoral outcomes) and Governmental decisions (through a seat at the table and quid pro quo arrangements between the contributor and the political party)-Plea of infringement of the right to privacy has no application at all if the donor makes the contribution, that too through a banking channel, to a political party-Amendment to S. 182 of the Companies Act is manifestly arbitrary for (a) treating political contributions by companies and individuals alike; (b) permitting the unregulated influence of companies in the governance and political process violating the principle of free and fair elections; and (c) treating contributions made by profit-making and loss-making companies to political parties alike-Electoral Bond Scheme, the proviso to S. 29C(1) of the Representation of the People Act, 1951 (as amended by S. 137 of Finance Act, 2017), S. 182(3) of the Companies Act (as amended by S. 154 of the Finance Act, 2017), and s. 13A(b) of the IT Act (as amended by s. 11 of Finance Act, 2017) are violative of Art. 19(1)(a) and unconstitutional-Deletion of the proviso to S. 182(1) of the Companies Act permitting unlimited corporate contributions to political parties is arbitrary and violative of Art. 14 [S. 11, 13(A)(b), Companies Act, S.182, Representation of the People Act, 1951 (as amended by s. 137 of Finance Act, 2017, Finance Act, 2017, S. 11, 135, 137 & 154, Companies Act, 2013, S. 182, Money Laundering Act, 2002, Reserve Bank of India Act, 1934, S. 31, Representation of the People Act, 1951, S. 29C(1), Art. 14, 19, 21, 32, Electoral Bond, Scheme, 7(4)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Domain name-Amount received for providing domain name registration services-Cannot be assessed as royalty-Appeal of assessee is allowed-DTAA-India-USA [Art. 12(3)(a)]

S. 4 : Charge of income-tax-Club-Bank-Interest-Mutuality-Interest on fixed deposits-Principle of mutuality does not apply to interest income earned on fixed deposit in the banks-Appeal of Revenue is dismissed on account of Monetary limits. [S. 268A. Art. 136]

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

S. 50: Offences and Prosecution-Failure to furnish foreign assets and financial interest in foreign entity-Wilful evasion of tax Act of 2015 was not in existence at relevant point of time-Non-disclosure in tax returns for year 2007-08 or 2009-10 cannot be used to prosecute under law coming into effect thereafter-Criminal Proceedings quashed-A legal fiction or a deeming fiction should not be extended beyond the purpose of the Act for which it is created or beyond the language deployed in the enactment. [S. 52, 72(c), Art. 20, 226]

S. 271B : Penalty-Failure to get accounts audited-Failure to submit audit report in time-Reasonable cause-Levy of penalty is not valid. [S.44AB, 273B]

S. 271(1)(c) : Penalty-Concealment-Furnishing inaccurate particulars of income-Sundry credits-Burden of proof on assessee-Order of Tribunal affirming the levy of penalty is affirmed.[S. 68, 260A]

S. 271(1)(c) : Penalty-Concealment-Furnishing inaccurate particulars of income-Sundry credits-Burden of proof on assessee-Order of Tribunal affirming the levy of penalty is affirmed by High Court-SLP is dismissed [S. 68, Art. 136]