S. 80GGC : Contribution-Any person-Political parties-Evidence not provided-Funds transferred to proprietor of firms and further transferred to other entities-Financial manoeuvre to legalize illicit money and to evade taxes-Disallowance is justified.

S. 80G : Donation-Charitable objects-Expenses are less than the prescribed percentage-Directed to allow the approval. [S. 80G(5)(vi)]

S. 80G : Donation-Charitable institution-No allegation that the Trust did not fulfil conditions required Under Section 80G(5)(vi)-Denial of approval is not valid. [S. 12AA, 80G(5)(vi)]

S. 74 : Losses-Capital gains-Amalgamation-Carry forward and set off-Long-term capital loss of amalgamating company-The benefit of carry forward and set-off has to be allowed to the amalgamated company-.Section 72A applies only in respect of accumulated losses and unabsorbed depreciation under the head Profits and gains of business or profession. [S. 72A]

S. 74 : Losses-Capital gains-Carry forward and set off by non-Resident-Capital losses which have been brought forward from earlier years have to be carried forward to the subsequent years without setting off the same against the capital gains of the relevant assessment year-DTAA-India-Mauritius. [S. 90, Art. 13(4)]

S. 73 : Losses in speculation business-Loss incurred on shares and derivatives could not be treated as speculation Loss-Gross total income comprised mainly of income from other sources much greater than income from business. [S.73, Expln.]

S. 72A : Carry forward and set off of accumulated loss and unabsorbed depreciation-Amalgamation-Amalgamation scheme approved by High Court-All three conditions of s. 72A(2) cumulatively and required of rule 9C fulfilled-Intention behind merger ratified-AO rightly directed by CIT(A) to allow set off losses of amalgamating company in hands of the assessee. [S. 72A(2)]

S. 72A : Carry forward and set off of accumulated loss and unabsorbed depreciation-Losses of amalgamating company-High Court approved the scheme of merger-The merger scheme cannot be disturbed by the Revenue by merely alleging that the merger was only to buy losses and that it is a colourable device. [R. 9C Companies Act, 1956 S. 391(7)]

S. 72A : Carry forward and set off of accumulated loss and unabsorbed depreciation-Amalgamation-Assessing Officer had rejected claim for carry forward of business loss-loss is not available to set off. [S. 79]

S. 69C : Unexplained expenditure-Bogus purchases-If purchases are accepted in subsequent years, information/reasons based solely on investigation wing report and on statement recorded of third party with no independent satisfaction of AO, no opportunity to cross-examine parties then reopening and addition not sustainable [S. 143(3), 147, 148]