S. 69C : Unexplained expenditure-Bogus purchases-Business of manufacturing and trading of tea machineries-PAN cards were furnished -Payments were made by account payee cheques -TDS was deducted – Parties were produced for examination -Addition cannot be made as unexplained expenditure.

S. 68 : Cash credits–Bank Account-Agricultural income-Bank statement is not considered as books of account and, therefore, any sum found credited in bank pass book cannot be treated as an unexplained cash credit-Matter remanded.

S. 68 : Cash credits-Share application money-Farmers- Identity, creditworthiness and also source of their investment was furnished -Addition is held to be not justified.

S. 54F : Capital gains-Investment in a residential house-Deduction cannot be rejected only on the ground that the builder failed to construct construction with in prescribed time. [S. 45]

S. 45 : Capital gains-Unexplained investment-Long term capital gains -Penny stocks -Sale of shares–Accommodation entries-Purchase and sale of shares had been made through Bombay Stock Exchange and through DMAT account-Sale proceeds to be assessed as long term and cannot be assessed as unexplained investment–Eligible exemption. [S. 10(38), 69, 131]

S. 40(a)(i) : Amounts not deductible-Deduction at source -Non-resident–Foreign agent-Commission–No permanent establishment in India–Carrying activities outside India-Payment is neither taxable nor can be treated as payment for rendering any managerial, technical or consultancy services [S. 9(1), 195]

S. 14A : Disallowance of expenditure-Exempt income–When there is no exempt income, no disallowance can be made. [R. 8D]

S. 250 : Appeal – Commissioner (Appeals) – power to admit additional evidence —Books of account and vouchers were produced before the AO -Commissioner (Appeals) can call for books of account, details and vouchers for examination — No violation of Rule 46A(4).[S.250(4) R. 46A ]

S. 219 :Credit for advance tax –Deduction at source- Advance received by firm -succession by company —Credit for deduction of tax at source should be allowed when the receipt or part of receipt recognised as income by company.

S. 145 : Method of accounting –Works contract-Composite contract – First year of business -Rejection of books of account is not justified –GP rate of 7.3% is held to be proper . [ S.145(3)