S. 145 : Method of accounting-Discrepancy in receipts as shown in 26AS-Estimation of income-Contractor-Without pointing out any defects in the books of account merely on the basis of discrepancy in in receipts as shown in 26AS and books of account addition cannot be made. [S. 68, 133(6), Form 26AS]

S. 145 : Method of accounting-Accrual of income-Unearned revenue-Additional evidence produced-Matter is remanded for reconsideration-Provision made reversed in next year-Remanded for verification. [S. 5, 40(a)(ia)]

S. 143(1)(a) : Assessment-Intimation-Insurance premium-Premature surrender of life insurance policy-Though TDS under section 194DA was contemplated on gross amount paid under a life insurance policy, but amount of income which could be added by means of adjustment under section 143(1)(a)(vi) would be such sum received as reduced by amount of premium paid. [S. 10(10D), 143(a)(vi), 194DA Form No. 26AS]

S. 115JB : Book profit-Disallowances made under section 14A read with rule 8D could not be applied to provision of section 115JB-Exempted income-Disallowance is restricted on an ad-hoc basis at rate of 1 percent of exempt income. [S. 14A, R.8D]

S. 115JB : Book profit-Sick company-Adjustment of brought forward business losses or depreciation would start after it become n00n-sick company. [S. 115JB(2)]

S. 115JB : Book profit-Foreign company-Section 90(2), overrides the provision of MAT-MAT provisions could not be applied even to foreign companies which have PE in India as it would be contrary to basic foundation of applicable treaty. [S. 90(2), Companies Act, 1956, Part II and Part III of Schedule-VI]

S. 115BBE : Tax on specified income-Survey-Undisclosed loan-Surrender of income-Statement retracted-Addition is deleted-Difference in closing stock-No evidence was found-Addition is deleted-Business income-Only source of income was business income, undisclose income embedded in undisclosed business transactions would not attract section 115BBE-Undisclosed income attributable to excess cash from other sources would attract section 115BBE. [S. 68, 69D, 133, 133A]

S. 115BBC : Anonymous donations-Religious trust-Survey-Cash deposited-Failure to explain the source-Addition cannot be made in the assessment of religious trust. [S. 11, 12, 68]

S. 94 : Transaction in securities-Short term capital loss-Sale of mutual funds-Units were purchased much before 3 months period prior to record date condition prescribed in clause (a) of section 94(7) was not satisfied and consequently provision of section 94 was not applicable on assessee-Commissioner (Appeals) was justified in giving relief of disallowance of STCL under section 94(7). [S. 94(7)

S. 90 : Double taxation relief-Foreign tax credit-Form No 67 filed after due date of filing of return but before completion of assessment-DTAA-India-UK. [R. 128, Art. 24]