S. 115JAA : Company-Book profit-Deemed income-Tax credit-Companies-Surcharge and cess- Irrespective of variation in its rate subsequently, would stand to be paid only for year for which tax is payable under regular provisions of Act, i.e., at an amount net of tax credit, and at rate applicable for that year-No question of set off of surcharge/cess, as in case of tax, in absence of specific provisions in its respect. [S. 4, 115JB]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Contracts with third party customers-Tested parties-Difference in margin rate falls within tolerance limit of 5 per cent, in which case, international transactions of assessee should be considered to be at arms length-Adjustment is deleted-Delay in receiving money-Interest was to be computed individually after allowing accepted credit period-Matter remanded.

S. 80P : Co-operative societies-Interest income from investments made in various Co-operative Banks-Entitle to deduction. [S. 80P(2)(d), 80P(4)]

S. 80P : Co-operative societies-Business of providing credit facility to its members-Matter remanded to the Assessing Officer.[S. 80P(2)(a)(i)]

S. 80G : Donation-Objects of general public utility-Trade, commerce or business related to such objects-Receipts does not exceed 20 percent of total receipts-PCIT is directed to adjudicate matter of approval in light of amended provisions of section 2(15) of the Act. [S. 2(15), 80G(5)]

S. 69C : Unexplained expenditure-Bogus purchases-Civil contractor-No specific defects in the books of account-Addition on account of bogus purchases to 10 per cent of turnover is affirmed. [S. 145(3]

S. 69A : Unexplained money-Cash deposited-Demonetization-Business of manufacture and retail trading of jewellery items-Actual sales cannot be treated as deemed income-Deletion of addition is affirmed. [S.143(3), 145(3)]

S. 69A : Unexplained money-Cash deposited-Demonetization period-Gifts received in connection with marriage-NRI-Failure to substantiate the gift-Relief of Rs.50,0000 is granted-Provisions of section 115BBE as amended by Taxation Laws (Second Amendment) Act, 2016 will apply with effect from 1-4-2017 on enhanced rate of 60 per cent instead of rate of 30 per cent. [S,115BBE]

S. 69A : Unexplained money-Cash seized-Failure to produce dosimetry evidence-Addition is affirmed. [S. 132]

S. 68 : Cash credits-Share application money-No enquiries made nor any evidence to reject documents filed by assessee, addition is not called for.