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 Invetsigation 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: 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. 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.