ITR’S TRIBUNAL TAX REPORTS

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Volume 125 : Part 1 (Issue dated : 7-7-2025)

SUBJECT INDEX TO SHORT NOTES OF CURRENT CASES

Appeal --Delay in filing--Condonation of delay--Sufficient cause--Liberal approach to be adopted--Delay condoned--Income-tax Act, 1961, s. 249(3)-- Mulund Samata Co-operative Housing Society Ltd. v. ITO (Mumbai) . . . 11

Assessment --Intimation--Assessee, a charitable trust--Assessing Officer making addition through intimation passed under section 143(1)--Assessee’s rectification application filed thereagainst rejected by order under section 154--Commissioner (Appeals), dismissing appeal as being controversial in nature and beyond ambit of section 154, refusing to interfere with order under section 154--Law applicable--Effect of amendment of section 143(1)--Specific requirement of adjustment, only in a case of prima facie admissibility or prima facie inadmissibility, no longer a condition precedent after amendment to section 143(1) by Finance Act, 1999, with effect from 1-6-1999--Held, no merit in assessee’s submissions that adjustment under section 143(1) cannot be made on debatable issue--Amended section 143(1) specifically requiring assessee be provided opportunity of hearing as well as consideration of its response, before making any adjustment--Commissioner (Appeals) justified in dismissing assessee’s appeal and upholding order under section 154--Commissioner (Appeals) not addressing merits of adjustments for technical reasons as assessee’s appeal only against order under section 154--No appeal against intimation--Assessee at liberty to appeal before Commissioner (Appeals) against intimation with application explaining delay in filing appeal--Commissioner (Appeals) to consider condonation of delay in interest of justice and decide appeal on merits--Income-tax Act, 1961, ss. 143(1) (as amended by Finance Act, 1999, with effect from 1-6-1999), 154-- Nariman Point Association v. ITO (Exemption) (Mumbai) . . . 1

Business expenditure --Foreign exchange loss--Treated as revenue expenditure by Tribunal in assessee’s own case--Held, Assessing Officer to compute total income treating foreign exchange loss as revenue expenditure--Income-tax Act, 1961-- Cheers Interactive (India) P. Ltd. v. ITO (Mumbai) . . . 9

----Intangible assets--Depreciation--Tribunal, in assessee’s own case, holding allowability of claim is either of charging depreciation over several years or in one go in impugned year as revenue expenditure--Tribunal allowing assessee’s alternate claim of treating it as revenue expenditure--Held, assessee’s claim allowable--Assessing Officer to recompute tax liability accordingly--Income-tax Act, 1961, ss. 32, 37(1)-- Cheers Interactive (India) P. Ltd. v. ITO (Mumbai) . . . 9

Business loss --Set-off and carry-forward of business loss--Assessing Officer disallowing set-off of business loss while computing total income--Commissioner (Appeals) confirming disallowance of set-off of unabsorbed depreciation owing to non-availability of loss for carry-forward to subsequent year--Matter not considered in right perspective--Matter remanded to Assessing Officer for decision afresh--Income-tax Act, 1961-- Cheers Interactive (India) P. Ltd. v. ITO (Mumbai) . . . 9

Capital gains --Non-resident--Taxability in India--Claim that short-term capital gains earned on sale of rights entitlement in shares of Indian company, not taxable in India--Revenue authorities concluding rights entitlement to be treated as shares, as it derived value from assessee’s existing shares--Dispute Resolution Panel, despite correctly observing that existing shareholder could subscribe to new shares “only by exercising” their rights entitlement, making incorrect conclusion--Assessee’s application to rectify issue of short credit of advance tax payment pending consideration before Assessing Officer--Held, rights entitlement to shares distinct from shares--Short-term capital gains earned by assessee from sale of rights entitlement taxable only in resident State--Additions to assessee’s income to be deleted--Issue of short credit of advance tax restored to Assessing Officer to grant credit thereon after necessary verifications--Income-tax Act, 1961, ss. 143, 144C--Double Taxation Avoidance Agreement between India and Saudi Arabia, art. 13-- General Organization for Social Insurance v. Asst. CIT (International Taxation) (Mumbai) . . . 4

Co-operative society --Special deduction--”Co-operative society”, meaning of--Co-operative bank a species of the genus “co-operative societies”--Interest income earned by co-operative housing society from investments with a co-operative bank held eligible for deduction under section 80P(2)(d)--Income-tax Act, 1961, s. 80P(2)(d)-- Mulund Samata Co-operative Housing Society Ltd. v. ITO (Mumbai) . . . 11

Income from other sources --Deductions--Assessee earning interest income from fixed deposits with banks--Keeping deposits as collateral security and margin money, assessee availing of credit facilities, paying interest thereon--Net interest income shown as interest received from bank and offered to tax under head “Income from other sources”--Assessing Officer making disallowance on ground interest expense not necessarily incurred to earn interest income--Assessee, a business entity, offering fixed deposit for enhancing loan security and bank guarantee--Assessee paying interest related to bank loan and bank charges--Adjustment made between interest paid and interest received--Otherwise, sum would be adjusted in profit and loss account--While disallowance made from interest received, sum eligible for adjustment against business income--Entire adjustment tax neutral--Held, addition unjustified and liable to be deleted--Income-tax Act, 1961, s. 57-- Global Tradex Ltd. v. Asst. CIT (Mumbai) . . . 7

Penalty --Concealment of income--Furnishing inaccurate particulars of income--Assessing Officer levying penalty under section 271(1)(c) on account of assessee’s wrong claim of exemptions under section 11(1) and (2)--Failure to specify limb of penalty in his twin show-cause notices--Held, vitiates entire proceedings--Income-tax Act, 1961, ss. 271(1)(c), 274-- Delhi Building and Others Construction Workers Welfare Board v. Deputy DIT (Exemption) (Delhi) . . . 16

Reassessment --Notice--Validity--Long-term capital gains--Sale of property--Original return filed by assessee accepted by Assessing Officer--Reopening of assessment based on search and seizure conducted at third-party premises, wherein two agreements of sale of assessee’s property mentioning different sale amounts to that in registered sale deed of premises found--Assessing Officer adopting amount taken from third-party premises to compute long-term capital gains--However, when notice issued, assessee already dead--Held, notice issued in name of dead person invalid--Effect of section 159(2)(b)--To undertake proceeding on deceased person, notice to be served upon only legal heir, as deemed assessee, within prescribed time-limit--No notice under section 148 served on original assessee when alive or subsequently within time on deemed assessee--Entire proceeding vitiated and void ab initio--Income-tax Act, 1961, ss. 143(3), 147, 148, 159(2)-- Deputy CIT v. Pranav Gupta (Delhi) . . . 13

PRINT EDITION

ITR (Trib) Volume 125 : Part 1 (Issue dated : 7-7-2025)

SUBJECT INDEX TO CASES REPORTED IN THIS PART

Advance tax --Interest on advance tax--Failure to deduct tax at source in computing interest--Assessing Officer to compute interest after deducting tax deductible at source--Income-tax Act, 1961, s. 234B-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Interest--International transactions--Definition--Subsequent retrospective amendment bringing transaction of allowing excess credit period to associated enterprise within ambit of international transaction--Transfer Pricing Officer recommending adjustment based on amendment and assessment made accordingly--Assessee at time of filing return not in position to anticipate subsequent amendment--Held, assessee not liable to pay interest on advance tax on basis of adjustment--Income-tax Act, 1961, ss. 92B, 234B-- Exquisite Jewellery v. ITO (Mumbai) . . . 117

Assessment --Fresh claim in assessment proceeding--No revised return filed--Claims made by letter before Assessing Officer--Computation of income and required evidence on record before Assessing Officer--Held, assessee entitled to raise additional claim before appellate authorities--Claim deserves to be considered afresh--Matter remanded to Assessing Officer--Income-tax Act, 1961, s. 143-- BMW India P. Ltd. v. Deputy CIT (Delhi) . . . 16

Best judgment assessment --Accounts--Rejection of books of account--Estimation of income--Fall in net profit rate compared to previous year--Failure to file return despite high turnover--Failure to have tax audit done--Addition at 10 per cent. of expenses by Assessing Officer held excessive--Held, addition restricted to 1.52 per cent. of turnover based on previous year’s accepted results--Income-tax Act, 1961, ss. 44AB, 139, 145(3), 148-- Adworld Communications P. Ltd. v. Deputy CIT (Jaipur) . . . 160

Business expenditure --Capital or revenue expenditure--Assessee-company, in business of providing services in custom research and data analytics across multiple sectors and in identifying technology licensing opportunities to address business innovation and technological needs of its various customers--Assessee undertaking such business transaction with EADS by entering into agreement and paying part of consideration per specified terms and conditions and guaranteeing to generate a minimum of Euro 50 million of net licensing revenues for EADS over a period of 10 years until year 2021 with specified minimum targets for each of year--Assessee reporting transaction in its audited financial statements as “intangible fixed assets” and claiming depreciation at 25 per cent.--Assessing Officer disallowing claim on ground assessee neither acquired any right or business of commercial rights of similar nature as contained in Explanation 3 to section 32(1) nor such rights put to use for assessee’s business purpose during year--Terms and conditions set forth in agreement analysed--Assessee demonstrating generation of revenue under agreement over period from 1-4-2010 to 31-3-2017--Held, expenditure incurred wholly and exclusively for purposes of business--To be treated as revenue in nature--Income-tax Act, 1961, ss. 32(1), Expln. 3, 37(1) -- Cheers Interactive (India) P. Ltd. v. Asst. CIT (Mumbai) . . . 149

----Deduction of interest expenditure--Mercantile system of accounting--Accrued interest on investment--Interest expenditure allowable deduction under mercantile accounting system on accrual basis--Assessee to furnish details of expenditure claimed--Matter restored to Assessing Officer to examine quantification and details of interest expenditure claimed--Income-tax Act, 1961, s. 36(1)(iii)-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Disallowance of purchase expenses--Commissioner (Appeals) disallowing each expense at ad hoc percentage in terms of Tribunal order for earlier year--Methodology not to be interfered with--Matter restored to Assessing Officer for verification that disallowance conforms with earlier Tribunal decision--Income-tax Act, 1961, s. 37-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Foreign exchange loss--Expenditure revenue in nature--Income-tax Act, 1961-- Cheers Interactive (India) P. Ltd. v. Asst. CIT (Mumbai) . . . 149

Depreciation --Lease rent assumed by Assessing Officer fixed prior to entering into agreement--Thereafter lease rent payable as percentage of monthly sales turnover--Partial reading of agreement by tax authorities improper--Lease rent receipts taxed in subsequent assessment year and depreciation claim allowed in both years--When income assessed to tax, tax authorities obliged to allow expenses incurred in earning income and deductions allowable thereon--“Income from other sources” also amenable to depreciation under section 32--Rejection of claim improper--Assessee’s claim of lease rental income in subsequent years allowed by Assessing Officer--Purchase and leasing out in nature of commercial transaction--Held, Assessing Officer not entitled to question assessee’s business prudence unless transaction sham or between two related parties--Disallowance of depreciation after accepting purchase cost unjustified--No enquiries carried out by Assessing Officer--Decision on mere suspicions and surmises--Claim of depreciation to be allowed--Income-tax Act, 1961, s. 32-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

Income --Accrual of income--Accrued interest from bonds--Bonds registered in assessee’s name by order of Special Court--Assessing Officer’s computation of accrued interest as assessee’s income to be sustained--Income-tax Act, 1961--Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Accrual of income--Interest on purchase of bonds--Assessee not considered owner of bonds by earlier Tribunal decision in assessee’s own case--No question of assessing accrued interest--Commissioner (Appeals) justified in deleting addition--Income-tax Act, 1961-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

Income-tax survey --Educational institution--Statements recorded during survey--Presumption that documents belong to assessee--Survey conducted on assessee, an educational institution, and in premises of third-party Q--Assessing Officer making additions without giving benefit of sections 11 and 12 based on documents seized at Q’s premises and assessee’s accountant’s confirmation--Presumption under section 292C not applicable to assessee since documents impounded from premises of not assessee but third-party--Assessing Officer not substantiating calculation sheets found at third-party premises pertaining to assessee and to be considered for taxation purposes--Held, statement recorded during survey of no evidentiary value and presumptions drawn under section 292C not in favour of Revenue--Addition to be deleted--Income-tax Act, 1961, ss. 11, 12, 133A, 292C-- Pushpa Vidya Niketan Samiti v. Asst. CIT (Jaipur) . . . 1

----Scope of section 133A--Section 133A not empowering authorities to record statements--Statements obtained during survey proceedings not to automatically bind assessee--Burden on assessee to rebut presumption--Income-tax Act, 1961, s. 133A-- Pushpa Vidya Niketan Samiti v. Asst. CIT (Jaipur) . . . 1

International transactions --Arm’s length price--Determination--Advertising, marketing and promotion expenditure--Transfer pricing adjustment made on ground that assessee’s group held valuable intellectual property including brand and that assessee had thus incurred expenditure on advertising, marketing and promotion--Reimbursement of such expenditure present in earlier years but absent in year under consideration--Agreement between assessee and associated enterprise did not show that assessee had agreed to promote brand of associated enterprise--Bright line test--Excess expenditure beyond bright line not automatically to be regarded as international transaction--Bright line test not stipulated in Act or Rules--Benchmarking can be carried out only if international transaction shown to exist--Existence of transaction not matter of inference--No evidence to establish occurrence of international transaction--Mere agreement allowing use of brand name insufficient--Held, adjustment deleted--Income-tax Act, 1961, ss. 92B, 92C-- BMW India P. Ltd. v. Deputy CIT (Delhi) . . . 16

----Arm’s length price--Determination--Intra-group services--For earlier year, Tribunal remitting issue to file of Transfer Pricing Officer--No reason shown to deviate from decision--Matter remanded--Income-tax Act, 1961, s. 92C-- BMW India P. Ltd. v. Deputy CIT (Delhi) . . . 16

Non-resident --Taxability in India--Rights entitlement--Short-term capital gains--Assessee’s claim of exemption of capital gain from sale of “rights entitlement” under article 13(6)--Disallowed by Assessing Officer on ground short-term capital gains falling within article 13(5) of Double Taxation Avoidance Agreement between India and Ireland, taxable in India under Act and to be set off against short-term capital loss--Dispute Resolution Panel holding rights entitlement and shares closely related assets taxable in source State, i. e., India--Under Double Taxation Avoidance Agreement between India and Ireland derivative deriving value from underlying equity not taxable in India under article 13(6)--Rights entitlement from shareholding not same as shares since rights shares allotted only on subscription--Held, rights entitlement, a distinct asset, that may be sold lapsed or subscribed akin to derivatives and not taxable in India--Rights entitlement shares and shares not closely related assets and not covered under article 13(4) and (5) so as to be taxed in country of source--Short-term capital loss incurred under Act read with article 13(5) not to be set off against short-term capital gain from sale of rights entitlement being not taxable in India--Income-tax Act, 1961, ss. 70, 71, 74--Companies Act, 2013, s. 62--Double Taxation Avoidance Agreement between India and Ireland, art. 13(4), (5), (6)-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

Rectification of mistakes --Mistake apparent from record--Error in computation sheet appended with order not disposed of by Assessing Officer though application filed under section 154--Held, Assessing Officer to rectify mistake apparent from record--Income-tax Act, 1961, s. 154-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

Search and seizure --Assessment in search cases--Money-market operations--Assessee declaring profit prior to date of search and loss subsequently--Assessing Officer making assessment per ledger account found during search, rejecting assessee’s declared loss--Transactions made in open market without delivery through running account with broker, to be squared off post delivery--No requirement to make payments--Disallowance of loss unjustified--Each transaction showing corresponding seller-buyer, who were unrelated third-parties--No material to show loss orchestrated or arranged--Loss in post-search period cannot render transactions bogus--Held, loss to be accepted--Addition to income unjustified--Assessing Officer to compute assessee’s total income reckoning assessee’s additional grounds of declared business loss, income from capital gains and income from other sources--Income-tax Act, 1961, s. 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Surrender of additional income to buy peace with Department--Surrender on basis of advance tax paid by all assessees of group--Identical addition deleted by Tribunal in case of assessee’s sister concern on ground books of account once accepted, addition based on income disclosure to be deleted--Following earlier decision, addition directed to be deleted even if reassessed income lower than sum surrendered--Income-tax Act, 1961, s. 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Addition for want of details from assessee--Commissioner (Appeals) not referring to assessee’s books of account showing purchase of shares--Assessing Officer could not have determined value of investment in non-existent company based on market price at beginning of year--Matter remanded to Assessing Officer for verification of facts--Income-tax Act, 1961, s. 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Addition of differences in value of shares between contract notes and information from shares-issuing companies and Custodian--Commissioner (Appeals) granting partial relief on account of information in contract notes, on conversion of debentures into shares at ratio wrongly reckoned by Assessing Officer, on year of purchase of shares wrongly taken by Assessing Officer--Revenue unable to controvert findings--Order of Commissioner (Appeals) upheld--Held, addition not to be made on basis of material collected behind assessee’s back without confronting assessee with it--Addition to be deleted--Income-tax Act, 1961, ss. 69, 132--Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Inventory of seized share certificates given to assessee for explanation of source of investment--Assessee’s request for details of shares and premises from where seized not acceded to--Assessee owner of shares only when registered in its name--Details of unregistered shares required to correlate shares with group entities--Relevant details sought by assessee not provided--Held, inventory insufficient to identify owner of shares--Order of Commissioner (Appeals) set aside--Assessing Officer directed to provide assessee break-up details with copies of share certificates and blank transfer deeds and re-examine matter--Income-tax Act, 1961, ss. 69, 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Purchase of public-sector-unit bonds--Commissioner (Appeals) granting partial relief on ground purchase of only some bonds not proved with evidence--Reference of Commissioner (Appeals) to Bombay Stock Exchange Bhav copy pertaining to debentures not bonds--Bonds purchased from brokerage firm with which assessee had running account, explaining non-payment therefor--Purchases duly accounted in books--No addition under section 69 in absence of any cash outflow--Held, tax authorities not justified in making addition--Addition to be deleted--Income-tax Act, 1961, ss. 69, 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Purchase of shares--Discovery of loose document during search showing valuation of certain shares--No physical share certificates found--Transaction usually undertaken through share brokers supported by broker notes--No credible evidence of purchase of shares or of money trail--Onus on Assessing Officer to show assessee made investments outside books or in assessee’s name not discharged--Assessee furnishing instances to show investment belonging to others--Similar addition made in earlier year deleted by Tribunal--Held, addition to be deleted--Income-tax Act, 1961, ss. 69, 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Sale and purchase of shares--Charge that assessee’s sale quantity of shares higher than purchase quantity--Commissioner (Appeals) finding that balance quantity of shares out of opening stock of shares--Held, restriction of addition by Commissioner (Appeals) to profit on sale of shares proper--Revenue unable to show otherwise--No question of unexplained investment--Income-tax Act, 1961, ss. 69, 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Sale and purchase of shares--Short-term capital gains--Assessee claiming lower profit than that computed by Assessing Officer on sale of shares--Assessing Officer’s computation based on selective information--Granting of relief by Commissioner (Appeals) based on complete information upheld--Held, addition to be deleted--Income-tax Act, 1961, s. 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained investment--Seizure of demand drafts taken in name of purchaser--Assessing Officer failing to make enquiries why drafts in name of purchaser when he assumed they belonged to assessee or that sold shares belonged to assessee--Statement of employee of purchaser denying sale of shares not brought on record--No explanation why drafts issued in purchaser’s name--Purchaser not shown to be subsidiary or benami of assessee--Only undisclosed income taxable--Demand drafts not obtained by assessee--Assessing Officer not finding real seller though fact ascertainable from broker notes--Held, Assessing Officer’s reliance on selective information to infer adversely against assessee legally unsustainable--No proof linking demand drafts with assessee--Addition unjustified and to be deleted--Income-tax Act, 1961, s. 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Assessment in search cases--Unexplained money--Receipt of bill-discounting charges--Addition made solely because deal concluded in assessee’s name though paid by brokerage firm, without any supporting material--Information relied upon not supplied to assessee on request--Material collected behind assessee’s back--Assessee furnishing ledger account of brokerage firm showing transaction duly accounted for--Income of brokerage already assessed reckoning impugned transactions--Affidavit of brokerage’s partner not considered--Held, no justification for assessing bill-discounting charges in assessee’s hands when payment not made by assessee--Addition to be deleted--Income-tax Act, 1961, ss. 69A, 132-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

Unexplained income --Assessee involved in money market operations--Additions on account of assessee’s lack of explanation of “receipts and payments account” of multiple bank accounts--Books of account cannot be prepared unless all bank transactions duly recorded--Bank deposits, once accepted as business transactions, not unexplained income as only income element therein assessable by Assessing Officer--Assessee’s inability to explain every bank deposit in wake of stock market scam to be appreciated--Record of transactions in books bars Assessing Officer from making addition based on details collected from Reserve Bank of India and vouchers--Under double-entry principle, both legs of transactions require examination--Held, Commissioner (Appeals) not justified in relying on Joint Parliamentary Committee report of scam when assessee explaining specific transactions of deposit--Addition to be deleted--Income-tax Act, 1961, ss. 68, 69A-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

SECTIONWISE INDEX TO CASES REPORTED IN THIS PART

Companies Act, 2013 :

S. 62 --Non-resident-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

Double Taxation Avoidance Agreement between India and Ireland :

Art. 13(4), (5), (6) --Non-resident-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

Income-tax Act, 1961 :

S. 11 --Income-tax survey-- Pushpa Vidya Niketan Samiti v. Asst. CIT (Jaipur) . . . 1

S. 12 --Income-tax survey-- Pushpa Vidya Niketan Samiti v. Asst. CIT (Jaipur) . . . 1

S. 32 --Depreciation-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

S. 32(1), Expln. 3 --Business expenditure-- Cheers Interactive (India) P. Ltd. v. Asst. CIT (Mumbai) . . . 149

S. 36(1)(iii) --Business expenditure-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

S. 37 --Business expenditure-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

S. 37(1) --Business expenditure-- Cheers Interactive (India) P. Ltd. v. Asst. CIT (Mumbai) . . . 149

S. 44AB --Best judgment assessment-- Adworld Communications P. Ltd. v. Deputy CIT (Jaipur) . . . 160

S. 68 --Unexplained income-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

S. 69 --Search and seizure-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

S. 69A --Search and seizure-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Unexplained income-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

S. 70 --Non-resident-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

S. 71 --Non-resident-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

S. 74 --Non-resident-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

S. 92B --Advance tax-- Exquisite Jewellery v. ITO (Mumbai) . . . 117

----International transactions-- BMW India P. Ltd. v. Deputy CIT (Delhi) . . . 16

S. 92C --International transactions-- BMW India P. Ltd. v. Deputy CIT (Delhi) . . . 16

S. 132 --Search and seizure-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

S. 133A --Income-tax survey-- Pushpa Vidya Niketan Samiti v. Asst. CIT (Jaipur) . . . 1

S. 139 --Best judgment assessment-- Adworld Communications P. Ltd. v. Deputy CIT (Jaipur) . . . 160

S. 143 --Assessment-- BMW India P. Ltd. v. Deputy CIT (Delhi) . . . 16

S. 145(3) --Best judgment assessment-- Adworld Communications P. Ltd. v. Deputy CIT (Jaipur) . . . 160

S. 148 --Best judgment assessment-- Adworld Communications P. Ltd. v. Deputy CIT (Jaipur) . . . 160

S. 154 --Rectification of mistakes-- Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. Asst. CIT (International Taxation) (Mumbai) . . . 128

S. 234B --Advance tax-- Growmore Research and Assets Management Ltd. v. Deputy CIT (Mumbai) . . . 44

----Advance tax-- Exquisite Jewellery v. ITO (Mumbai) . . . 117

S. 292C --Income-tax survey-- Pushpa Vidya Niketan Samiti v. Asst. CIT (Jaipur) . . . 1