“Section 67(2)”

Where purchases are accepted as genuine and a deduction allowed, the corresponding liability cannot be added under Section 68. The case also provides authority on the application of Section 69C when suppliers are non-genuine but the purchases themselves are not doubted.

To disallow long-term capital gains, the Assessing Officer must rely on cogent proof, not mere suspicion or presumption, regarding share price manipulation or the nature of the companies involved.

M/s E Zest Solutions Ltd. is a good comparable company and should be retained for transfer pricing benchmarking purposes.

The requirement to file Form 67 by the due date for claiming foreign tax credit is directory, not mandatory, if filed before the completion of assessment proceedings.

For a bad debt to be allowable as a deduction, it must be a debt that, if good, would have increased the taxable profits. An expenditure for running a school for employees' children in a remote area can be considered an allowable expenditure for the welfare of employees.

A revised return obliterates the earlier return filed by the assessee. The assessment must be completed considering only the revised return.

The ITAT held that failure to file Form 67 by the due date for filing the return of income is not fatal to the claim for foreign tax credit. The appellate authority can condone the delay in filing Form 67.

The time limit for filing Form 67 to claim foreign tax credit is directory, not mandatory. If no negative consequences are contemplated for non-adherence, the provision is considered directory.