S. 74: Losses-Capital gains-Capital loss-Carry forward and set off-Shares acquired before 1st April, 2017 cannot be taxed in the source country i.e., India-Eligible to carry forward the long term capital loss under the provisions of the Act-Debatable issue-Adjustment was not valid-DTAA-India-Singapore [S.90,143(1), Art. 13]

S. 69A: Unexplained money-Cash deposits in bank account-Demonetization period-Assessee, aged 89 years-Addition cannot be sustained to the extent of Rs. 5 lakhs in view of CBDT Instruction No. 3 of 2017, dt. 21st Feb., 2017-Source of the remaining amount of Rs. 5 lakhs has been duly explained by the assessee on the basis of said bank statements-Addition was deleted.

S. 69: Unexplained investments-Income from undisclosed sources-Search-Notings on loose paper-Third-party presumption-Failure to give an opportunity of cross-examination-Addition was deleted. [S.132, 132(4)]

S. 69: Unexplained investments-Income from undisclosed sources-Survey-Investment in immovable property-AO was right in bringing the undisclosed income to tax under the special provisions of S. 69 and thereafter levying tax under the provisions of S. 115BBE.[S.69B, 115BBE, 292B]

S. 68: Cash credits-Share transactions-Capital gains-Cannot be assessed as sham transaction-Addition was deleted. [S. 10(38,45]

S. 56: Income from other sources-Difference between the stamp duty value as on the date of agreement and the agreement value of the flats-Reference to DVO-Issue is restored to the AO for de novo adjudication after seeking a valuation report from the DVO as per the provisions of the Act. [S.50C(2), 56(2)(vii)(b)]

S. 56: Income from other sources-Shares purchased for trading purposes-Stock in trade-Shares purchased for trading purposes, provisions of section 56(2)(viia) cannot be applied. [S. 562(viia)]

S.54F: Capital gains-Investment in a residential house-Purchase of house property-Execution of sale deed beyond the specified period-MoU on 21st Aug., 2015-Entitled to exemption. [S. 45]

S. 40(a)(i): Amounts not deductible-Deduction at source-Non-resident-Payment of freight charges to foreign shipping companies-Disallowance was affirmed.[S. 5(2), 195]

S. 37(1): Business expenditure-State tax paid in USA-Not claimed any benefit of the tax paid in the USA under the provisions of S. 90/91-State tax paid in USA is allowable as deduction.