S. 69C : Unexplained expenditure-Transactions through Banking Channels-Deletion of addition is affirmed.

S. 68 : Cash credits-Unsecured loans-Filed confirmations, copies of returns, bank statements-Burden discharged-Order of CIT(A) deleting the addition is affirmed.

S. 68 : Cash credits-Share capital and share premium-Proved source and also source of source-Addition is not justified. [S.133(6)]

S. 56 : Income from other sources-Receipt of shares of closely held company for inadequate consideration or without consideration-Amalgamation-Shares received by assessee-company on account of amalgamation for price lower than fair market value-Not within ambit of specific exclusions-Charge attracted-Matter of valuation remanded-Receipt of shares does not stipulate transfer of shares-Interpretation of taxing statutes-Specific charging provision-General provision will give way to specific Provision-Assessment-Protective or Precautionary addition permissible. [S. 2(IB), 2(14) 47(vi), 56 (2)(viia)]

S. 45 : Capital gains-Entity forming consortium with equal shares-Assessee transferring shares in consortium-Cost indeterminate Deleting addition-Order of CIT(A) deleting the addition is affirmed.

S. 45 : Capital gains-Business income-Sale of flats-Intention to hold the same as investment-Income chargeable to tax as capital gains and not business income-Unsold flat generating rental income cannot be treated as stock-in-trade-Res Judicata-No material changes in facts and law-Revenue is not permitted to take different view in subsequent years. [S. 28(i)]

S.43B : Deductions on actual payment-Provision for leave encashment-Disallowance is upheld.[S.43B(f)]

S. 40(a)(ii) : Amounts not deductible-Rates or tax-Tax includes Cess-Education cess is not deductible.

S.37(1) : Business expenditure-Interest paid on excess refund of duty drawback-Not penalty or fine-Allowable as deduction. [S. 37, Expln. 1,145, Customs And Central Excise Duties Drawback Rules, 2017, R. 17]

S. 36(1)(iii) : Interest on borrowed capital-Investments in special purpose vehicles-Interest is allowed as deduction-Bad debt-Additional claim first time in the course of assessment-Allowed as deduction.[S. 36(1)(vii), 251]