S. 115JB : Book profit-Foreign company-Section 90(2), overrides the provision of MAT-MAT provisions could not be applied even to foreign companies which have PE in India as it would be contrary to basic foundation of applicable treaty. [S. 90(2), Companies Act, 1956, Part II and Part III of Schedule-VI]

S. 115BBE : Tax on specified income-Survey-Undisclosed loan-Surrender of income-Statement retracted-Addition is deleted-Difference in closing stock-No evidence was found-Addition is deleted-Business income-Only source of income was business income, undisclose income embedded in undisclosed business transactions would not attract section 115BBE-Undisclosed income attributable to excess cash from other sources would attract section 115BBE. [S. 68, 69D, 133, 133A]

S. 115BBC : Anonymous donations-Religious trust-Survey-Cash deposited-Failure to explain the source-Addition cannot be made in the assessment of religious trust. [S. 11, 12, 68]

S. 94 : Transaction in securities-Short term capital loss-Sale of mutual funds-Units were purchased much before 3 months period prior to record date condition prescribed in clause (a) of section 94(7) was not satisfied and consequently provision of section 94 was not applicable on assessee-Commissioner (Appeals) was justified in giving relief of disallowance of STCL under section 94(7). [S. 94(7)

S. 90 : Double taxation relief-Foreign tax credit-Form No 67 filed after due date of filing of return but before completion of assessment-DTAA-India-UK. [R. 128, Art. 24]

S. 81C : Undertakings-Special category states-Manufacturing of plastic packaging products such as PET and HDPE bottles-Eligible for deduction. [S. 80-IC (2)(a)]

S. 72 : Carry forward and set off of business losses-Foreign companies-Franchise fees from an Indian company-Rate of tax is not relevant-Loss is allowed to be set off. [S. 115A(1)(b)]

S. 69C : Unexplained expenditure-Bogus purchases-Trading and manufacturing of diamonds-Purchases form tainted dealers-Report of Task Force for Diamond Sector constituted by Ministry of Commerce and Industry-Profit element embedded in value of disputed purchases for diamond manufacturers was to be estimated in range of 1.5 per cent to 4.5 per cent [S. 40A(3), 145]

S. 69C : Unexplained expenditure-Ad-hoc addition of sundry creditors-20 percent of purchases-Discrepancies in balance sheet was reconciled-Addition is not valid. [S. 145]

S. 69A : Unexplained money-Hospital-Demonetization-Sale of medicine and cash in hand-Direction of commissioner to increase declared book profit by 4 per cent of total amount deposited by assessee-Addition is deleted. [S. 145.]