S. 90 : Double taxation relief-Elimination of double taxation-OECD Model Convention, Art, 25, 23A-No foreign tax paid in India-eligible for tax credit. [ S.40(a)(ii)]

S. 90 : Double taxation relief-Foreign tax credit-Form No. 67 was filed beyond due date of filing of return-Procedural-Not mandatory-Directory-Matter is remanded to Assessing Officer to grant FTC-DTAA-India-Myanmar [ S.139(1), 143(1), R. 128, art.25]

S. 80P : Co-operative societies-Tapping toddy from their farms-Sold through licensed shops-Not entitle to deduction. [S.80P(2)(a), 80P(2)(a)(iii), 80P(2)(a)(vi)]

S. 80P : Co-operative societies-Credit facilities to members-Interest on parking surplus funds in fixed deposits-Interest income is allowed as deduction. [ S. 80P(2)(a)(i)]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Liquidated damages-Sale of scrap-Miscellaneous income-Sundry creditors written back-Eligible for deduction.

S. 79 : Carry forward and set off losses-Change in share holdings-Companies which public are not substantial interested-Beneficially held more than 51 per cent of voting powers in both the years-The year in which the loss is incurred and the year in which the loss is sought to be set off-Share holding of one share holder is increased from 40 percent to 85 percent-Set off of brought forward losses is allowable.

S. 69C : Unexplained expenditure-Survey-Loose papers-Cash expenses-Unexplained receipts and expenditure-Order of CIT(A) is affirmed. [ S. 133A]

S. 69A : Unexplained money-Sale of land-Share holders-Unaccounted cash-Addition is deleted.

S. 69 : Unexplained investments-Income from undisclosed sources-Gift-Father and mother-Affidavits-Accepted as genuine-Gift from grand mother-Failure to produce evidence-Addition is affirmed. [ S.68]

S. 69 : Unexplained investments-Genuineness of purchases-Parties have not filed the return-No confirmation from the books of account of those parties-Addition is affirmed.