S. 143(1)(a) : Assessment-Intimation-Insurance premium-Premature surrender of life insurance policy-Though TDS under section 194DA was contemplated on gross amount paid under a life insurance policy, but amount of income which could be added by means of adjustment under section 143(1)(a)(vi) would be such sum received as reduced by amount of premium paid. [S. 10(10D), 143(a)(vi), 194DA Form No. 26AS]

S. 115JB : Book profit-Disallowances made under section 14A read with rule 8D could not be applied to provision of section 115JB-Exempted income-Disallowance is restricted on an ad-hoc basis at rate of 1 percent of exempt income. [S. 14A, R.8D]

S. 115JB : Book profit-Sick company-Adjustment of brought forward business losses or depreciation would start after it become n00n-sick company. [S. 115JB(2)]

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)]