S. 115JB : Company-Book profit-Revaluation of lands-Merger-Clause (J) in Explanation 1 to section 115JB(2), would be applicable from assessment year 2013-14 onwards only and thus, Assessing Officer was not correct in invoking clause (J) of Explanation 1 and making adjustments in book profits on account of revaluation of lands in profit and loss account for assessment years 2011-12 and 2012-13.

S. 90 : Double taxation relief-Rate of tax-Dividend Distribution Tax (DTAA)-Refund of DDT paid at a rate exceeding that specified in DTAA-Not justified in claiming beneficial rate on dividends, as specified in Double Taxation Avoidance Agreement-DTAA-India-Denmark-Singapore-[S.115O , art. 10, 11]

S. 90 : Double taxation relief-Foreign tax credit (FTC) cannot be disallowed for delay in filing Form 67 as filing of Form 67 is a directory requirement-DTAA-India-USA. [R. 128(9), Form, 67, Art. 25]

S. 80P : Co-operative societies-Requirement of making a claim in return of income under section 80A(5) is directory-Deduction under section 80P(2)(a)(i) and 80P(2)(d) is to be allowed. [S. 80A,80A(5), 80AC , 80P(2)(a)(i), 80P(2)(d) , 139(1)]

S. 80G : Donation-Donations which formed part of spend towards CSR-Allowable as deduction. [S.37(1)]

S. 80G : Donation-Accumulated substantial funds for building construction-No clear alignment with its charitable objectives. [S. 2(15), 12AA]

S. 69A : Unexplained money-Cash deposits-Demonetization-Sale in the course of business-Addition is deleted.

S. 68 : Cash credits-AIR information-Interest-Neither claimed credit for interest nor credit for tax deduction at source-Addition is deleted. [S.133(6), 194A]

S. 68 : Cash credits-long-term capital gain-Sale of equity shares of NCL Research and Financial Services Limited-Penny stock-Capital gains treated as bogus-Denial of exemption is affirmed. [S.10(38) , 45]

S. 68 : Cash credits-Capital gains-Penny stock-Failure to prove the genuineness-Denial of exemption is affirmed.[S.10(38), 45]