“Section 161(1)”

Fee under section 234E cannot be charged for the period prior to 01.06.2015, as the power to charge such fee was vested with the prescribed authority only upon substitution of clause (c) to section 200A by the Finance Act, 2015, effective from that date.

Income does not arise or accrue when the right to receive payment or compensation is inchoate, contingent, or in dispute, as such a right does not create a debt. This principle determines the correct year of taxability, particularly for compensation under litigation.

Where the shares of beneficiaries in a trust are determinate, trustees must be assessed separately for each beneficiary's share, treating each beneficiary as an individual. The income is then taxed at the marginal rate applicable to individuals, not at the maximum rate for an association of persons.

An assessee fails the 'Human Probability Test' when they cannot establish the genuineness of a claim for exempt income under section 10(38) and attempt to conceal unaccounted cash. Share transaction profits credited to an assessee's bank account must be added as income under section 68 if the receipt cannot be explained.

Contractual liabilities are allowable deductions in the year the liability is incurred, even if disputed by the assessee, rather than the year of actual payment or dispute resolution.

A statement recorded during a search cannot be the sole basis for an addition to income, especially if made in violation of CBDT instructions and the provisions of section 132(4).

ESOP compensation expenditure and the discount on the issue of ESOPs are allowable as deductions under Section 37(1) of the Income Tax Act.

Electronic records downloaded from electronic items cannot be relied upon at face value and require corroboration with other evidence for income-tax additions.