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]
S. 81C : Undertakings-Special category states-Manufacturing of plastic packaging products such as PET and HDPE bottles-Eligible for deduction. [S. 80-IC (2)(a)]
S. 72 : Carry forward and set off of business losses-Foreign companies-Franchise fees from an Indian company-Rate of tax is not relevant-Loss is allowed to be set off. [S. 115A(1)(b)]
S. 69C : Unexplained expenditure-Bogus purchases-Trading and manufacturing of diamonds-Purchases form tainted dealers-Report of Task Force for Diamond Sector constituted by Ministry of Commerce and Industry-Profit element embedded in value of disputed purchases for diamond manufacturers was to be estimated in range of 1.5 per cent to 4.5 per cent [S. 40A(3), 145]
S. 69C : Unexplained expenditure-Ad-hoc addition of sundry creditors-20 percent of purchases-Discrepancies in balance sheet was reconciled-Addition is not valid. [S. 145]
S. 69A : Unexplained money-Hospital-Demonetization-Sale of medicine and cash in hand-Direction of commissioner to increase declared book profit by 4 per cent of total amount deposited by assessee-Addition is deleted. [S. 145.]
S. 69A : Unexplained money-Immoveable property-Survey Draft sale deed-Not signed-Application filed by developer before Settlement Commission admitting to have invested certain amount of unaccounted income was not provided for confrontation-Addition is deleted. [S. 133A, 148]
S. 69A : Unexplained money-Deposit-Sale proceeds of book and donation-Matter remanded for reverification. [S. 147, 148]
S. 69 : Unexplained investments-Investment in purchase of house-Addition restricted to Rs. 1,81,700 only. [S. 144, 147, 148]