S.70: Set off of loss – One source against income from another source – Same head of income – arrangement of affairs within legal framework through legitimate means to reduce its tax liability – no evidence on record to doubt genuineness of transactions – STCL derived by assessee could not be prevented from being set off against LTCG. [ S. 45 ]
S. 69C : Unexplained expenditure – Information from Investigation wing – The AO cannot proceed to disallow only the purchases in isolation and the Tribunal disallowed the purchases at 12.5%. On appeal for A.Y. 2014-15, the Tribunal observed that the Assessee had only made payments towards purchases from previous year, hence the addition for A.Y. 2014-15 was unjustified. [ S. 147 , 148 ]
S. 69C: Unexplained expenditure – Search and seizure – Unabated assessment – Purchases are recorded in regular books of account- Order of CIT(A) deleting the addition is affirmed .
S. 69A: Unexplained money – Cash found in the work premises – Sales – Matter restored to AO to consider the evidence submitted. [ S. 131, 133A]
S. 69A: Unexplained money- Cash deposit – Demonetisation- Cash sales – Deletion of addition is affirmed by the Tribunal . [S. 68 ]
S. 68: Cash credits -Share application- Share premium- Identity and creditworthiness and genuineness is established – Addition is deleted.
S. 68: Cash credits – Share capital – Share premium- Proved the identity, credit worthiness and genuineness by documents –Addition is deleted. [ S. 133(6) ]
S. 68:Cash credits – Identity and creditworthiness is established -b The loan was repaid through banking channels- Addition is deleted . [ S. 147, 148 ]
S. 68: Cash credits -Unsecured loan- The assessee satisfactorily explained the source of the loan, and the lender’s credibility was established through the repayment in cheque and the lender’s business activity. The addition is deleted . [ S.133(6) ]
S. 68: Cash credits – Deposit in bank – The deposits are backed by equivalent withdrawals or immediate transfers, the entire deposit amount should not be treated as unexplained income- Net profit rate of 1 per cent on entire deposit is confirmed . [ S. 148 ]