S. 10 (23C) : Educational institution-Solely for educational purposes and not for purposes of profit-Profits of business not exempt unless business incidental to attainment of objectives and separate books of account maintained in respect of such business-Institution should also comply with provisions of State laws regulating activities of charitable institutions-Commissioner not bound to examine only objects of institution-Free to call for audited accounts or documents for recording satisfaction whether institution genuinely seeks to achieve objects-Prospective declaration of law-Appeals against rejection of applications for approval-Appeals dismissed-Law declared departing from previous rulings-Applications to be considered in light of subsequent events disclosed in fresh applications-Law declared by Supreme Court to operate prospectively-Interpretation of taxing statutes-Literal interpretation-Proviso[S. 2(15) 10(23C(vi) 11(4A), Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987, S 1(3)(A), 2(4), (5), 43, 44.]

S. 10(10AA) : Leave salary-Employee of the Central Government or State Government-Encashed earned leave by employees Government employee-Tamil Nadu Agricultural University-Funded by State Government and under its control-Retired Employees Of Tamil Nadu Agricultural University-Entitled to exemption. [S. 192(2A), Tamil Nadu Agricultural University Act, 1971, S. 7, 9]

S.43B: Deductions on actual payment – Adjustment u/s 143(1)(iv)(a)- Disallowance under section 36(1)(va) of the Act – Assessing Officer could not make disallowance based on observations made in Tax audit report that payments were made after due date specified under respective Acts- Adjustment u/s 143(1)(iv)(a) of the Act is bad in law – Judgement of Supreme Court in Checkmate Services Pvt Ltd v. CIT (2022) 448 ITR 518/ 218 DTR 218 / 143 taxmann.com 178 (SC) was rendered in the context where the assessment was farmed under section 143(3) of the Act hence not applicable when the adjustment is made u/s 143(1) of the Act. [ S. 2(24), 36(1)(va) , 139(1), 143(1), 143(i))(a)(v) ]

S. 272A : Penalty-Failure to answer questions-Sign statements-Furnish information-Illness of managing trustee of trust-Reasonable cause-Levy of penalty is not valid. [S. 139, 272A(2)(e), 273B]

S. 271G : Penalty-Documents-International transaction-Transfer pricing-Bench marking is accepted-Deletion of penalty is valid. [S. 92C, R. 10D(1)]

S. 271G : Penalty-Documents-International transaction-Transfer pricing-Valid satisfaction not recorded-Levy of penalty is not valid. [S. 92CA, 92D, 271(1)(c)]

S. 271BA : Penalty-Failure to furnish reports-International transaction-Transfer pricing-Bona fide belief-levy of penalty deleted. [S. 92CA, 92E]

S. 271(1)(c) : Penalty-Concealment-Disallowance of claim-mistakenly not added foreign exchange fluctuation amount to his income-Levy of penalty is not valid.

S. 271(1)(c) : Penalty-Concealment-Not specifying the charge-Bogus purchases-Levy of penalty is not valid. [S. 153A, 274]

S. 268A : Appeal-Monetary limit-Tax effect of quantum addition under dispute by revenue was less than prescribed monetary limit as fixed by relevant CBDT Circular, revenue’s appeal was to be dismissed.