S. 254(1) : Appellate Tribunal- Additional ground on question of law can be raised before Tribunal even in second round of appeal – Royalty received from overseas subsidiary from Egypt shown as taxable in the original return of income – Though the issue of taxability was not raised in the first round of appeal, additional ground was raised before the Tribunal in the second round of appeal – Tribunal allowed the claim and set aside the matter for verification- DTAA-India – Egypt [ Art. 13 ]

S.68: Cash credits – Suspicious transaction in shares- Penny stocks -Capital gains – Increase of 432% with in six months without any economic or technical basis -Purchasers could not be located-Transfer deeds did not bear the names or other particulars of the sellers-Prices on exchange was manipulated by two brokers in a systematic manner -Seller , broker , purchasers are located in different cities – Purchase and sale transactions in shares have been executed off market without in fact even fulfilling the reporting requirements in respect thereof under the regulatory frame work .- Additions confirmed as cash credits treating the transactions as bogus . [ S.45, 54F ]

S.68: Cash credits – Suspicious transaction in shares- Penny stocks -Capital gains – Off market transactions for which payments were made in cash- Predated contracts – Genuineness was doubted – Addition was held to be justified .[ S.10(38), 45 ]

S.45: Capital gains – Suspicious transaction in shares- Penny stocks -No defect in the papers support of the transactions, the suspension of the broker by SEBI will not hold the transaction invalid- Addition as cash credits is held to be not valid .[ S.68 ]

S.45: Capital gains – Suspicious transaction in shares- Penny stocks
-Copies of the physical share certificates DEMAT account statement confirmation of the transactions of buying and selling of the said shares by the respective stock brokers, receipt of sale proceeds through banking channels, etc- Addition cannot be made as cash credits [ S.68 ]

S.45: Capital gains – Suspicious transaction in shares- Penny stocks- Chain of transactions have been proved by evidence such as contract notes, DEMAT account , and payments through banking channel-Addition cannot be made as cash credits .[ S. 68 ]

S.45: Capital gains- Suspicious transaction in shares- Penny stocks- Sale through Ahmedabad Stock exchange – Statement of Mukesh Choksi relied without furnishing the same to the assessee- Addition is held to be not valid

S.45: Capital gains- Suspicious transaction in shares- Penny stocks- Purchases of earlier years were not doubted – Shares were sold through DEMAT account- Addition cannot be made as cash credits- Burden is on revenue .[ S.68 ]

S.69: Unexplained investments- AIR information- Firm purchasing the land in the name of partner – Addition cannot be made in the hands of the partner on the ground that PAN of partner is shown in the registration deed .

S.69: Unexplained investments- AIR information- Professional income shown by the assessee was exceeded the figure shown in the AIR information -Second owner- When the identity of first owner is established and assessed to tax – Addition cannot be made merely on the basis of AIR information.