“Section 187(1)”

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

Where a duty is cast on the payer to deduct and pay tax at source under Section 195, the payee-assessee cannot be levied interest under Section 234B for failure to pay advance tax if the payer defaults on its TDS obligation. This principle may also extend to interest under Section 234C.

The phrase "any sum" in Section 68 of the Income-tax Act refers only to a "sum of money" or "physical receipt," and does not include non-cash transactions, book entries, notional adjustments, or payments in kind.

An addition under Section 68 for cash credits cannot be made if the assessee has not commenced its business operations.

Depreciation is allowed on a building used for business purposes, following the rule of consistency, especially when depreciation was allowed in earlier assessment orders. Depreciation is granted on the block of assets, not individual assets, under section 32(1).

Payment of taxes under the Voluntary Disclosure of Income Scheme (VDIS) is to be treated as an application of income for trust purposes. The Gujarat High Court in CIT v. Ganga Charity Trust Fund (1986) 162 ITR 612 (Guj) followed the Madras High Court in Commissioner of Income Tax v. Janaki Ammal Ayya Nadar Trust (1985) 153 ITR 159 and the Andhra Pradesh High Court in Munna Lal and Sons v. CIT (1991) 187 ITR 378.