S. 45 : Capital gains-Sale of shares-Mode of Computation-Non-Resident corporate entity-Sale of shares to another shareholder-Independent parties-Valuation report-Disregarding agreement value between assessee and other shareholder is not justified Section 50CA which was introduced by Finance Act, 2017 with effect from 2018-19 is inapplicable to year in question-Addition is not valid-Difference between income returned and that reflected in Form 26AS-Assessing Officer is directed to verify and reconcile. [S. 48, 50CA]

S. 45 : Capital loss-Sale of shares-Related entity-Avoidance of tax-Sham transaction-Capital Loss-Transactions not colourable device-Disallowance of long-term, and short-term, capital loss is not justified-Carry forward and set off-Amalgamation-Entitled to manage its business affairs as it deems fit within legal framework-Loss is allowable. [S. 72, Companies Act, 2013,S.19]

S.43B: Deductions on actual payment-Statutory dues-Write-Back from taxable income-Provision offered to tax in earlier year and written back in subsequent year not taxable-Matter remanded for verification.

S. 43A : Rate of exchange-Foreign currency-Business expenditure-Capital or revenue-External commercial borrowing loans-Loss on reinstatement of external commercial borrowing-Mere reinstatement of losses per Accounting Standards without actual payment or remittance-Addition cannot be made-Additional ground is admitted. [S.37(1), 254(1)]

S. 40A(2): Expenses or payments not deductible-Excessive or unreasonable-Payment to related parties-Deletion is justified. [S.40A(2)(b)]

S. 40A(2): Expenses or payments not deductible-Excessive or unreasonable-Service charges paid to group company-Common management services-Disallowance is deleted.

S. 40(a)(ia): Amounts not deductible-Deduction at source-Mobilisation advance-Joint venture-Issue restored to Assessing Officer for verification.

S. 40(a)(ia): Amounts not deductible-Deduction at source-Payments to contractors and professional or technical service fee-Deducted lower rate of tax-Disallowance is not justified.[S.194C, 194J]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission-Disallowance is deleted.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission expense-Additional ground not considered-Matter remanded for de novo consideration. [S. 254(1)]