S. 164 : Representative assessees-Charge of tax-Private discretionary trust-Shares of beneficiaries were indeterminate or unknown-Trust under will-Assessable as total income of an Association of persons-Deeming fiction cannot extend to an extent denial of deduction-Chapter VI-A-Deduction under section 80C and 80TT is available. [S. 2(31), 80C, 8OTT,160(1)(iv), 164(1)(ii), 167B]

S. 153A: Assessment-Search-Unabated assessments-No incriminating material is found-Addition is deleted. [S.68, 69, 69C, 132]

S. 153A : Assessment-Search-Undisclosed income-Less than Rs.50 lakhs-Reassessment beyond six years is bad in law-Reassessment is bad in law. [S. 69, 132]

S. 153A : Assessment-Search-Cannot make a fresh claim for deduction under section 80-IA(4) for first time in return of income filed in response to notice issued under section 153A, pursuant to search conducted under section 132, in unabated/completed assessment as on date of search-In case of abated assessments, like Assessing Officer who can make assessment based on incriminating materials and any other information made available to him, including information furnished in return of income, assessee can claim all deductions towards any income or expenditure including under section 80IA(4), [S.80IA(4), 132, 139(1), 143(3)]

S. 115JB : Company-Book profit–Minimum alternate tax Banks constituted as corresponding new banks in terms of Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 and not registered under Companies Act, 2013 or any other previous company law, would not fall under provisions of section 115JB-Tax on book profits (MAT) would not be applicable to such banks. [S. 2(26), 115JB(2), Banking Regulation Act, 1949,S. 29, 51, Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 S.3(1), 11,Companies Act, 2013, S. 129]

S. 80P : Co-operative societies-Net surplus out all maintenance expenses-Interest income-Bank fixed deposits-Eligible deduction-Assessee had rightly set off interest income against maintenance expenses and addition made on this account was liable to be deleted..[S. 56, 57, 80P(2)(c) (ii)]

S. 80IE : Undertakings-North-Eastern states-Manufacturing pharmaceutical products and products developed in research and development centres-Allocation of expenditure-Unrelated to products manufactured in Sikkim unit-Allocation of research and development expenditure to Sikkim unit is wrong.[S. 35]

S. 80G : Donation-Time limit for applying for regular registration-Provisional application up to Assessment year 2024-25-Application in Form 10AB within six months before expiry of provisional approval-Application is within prescribed time limit-Matter is remanded to the file of CIT(E). [S.80G(5)]

S. 80G : Donation-Granted provisional registration-Prior to expiry of due date application was filed-Rejection order is set aside and matter is remanded with a direction to treat assessee’s application dt. 22/08/2023 as filed within time limit.[S.80G(5)(iv)]

S. 80G : Donation-Approval-Rejection of application by Commissioner (E) is not valid on plea that assessee was required to file application on or before 30-9-2022-Matter restored to file of Commissioner (E) for de novo consideration.[S.80G(5), Form No.10B]