“Section 179(3)”

Foreign Tax Credit (FTC) is allowable even if no tax is paid in India on the corresponding income due to deductions under sections 10A or 10AA, or losses in other units. The scope of income eligible for deduction under Section 10AA includes interest on deposits and realized gains on forward contracts.

Strong suspicion, no matter how compelling, cannot take the place of concrete evidence when making tax assessments, and additions to income cannot be sustained solely on that basis.

Disallowance under Section 40A(3) of the Income-tax Act, 1961, is not justified for cash payments if they are genuine, made out of business expediency, and the assessee's bona fides are not disputed, even after the 2009 amendments to the section.

A statement made to tax authorities, even in the absence of proof of coercion or pressure, cannot be taken as conclusive evidence. Additions to income cannot be made solely by relying on such a statement, particularly if it is retracted.

A transaction, even if appearing to be in the capital field or recorded as such, can constitute an 'adventure in the nature of trade,' leading to taxable income from business rather than capital gains.

Income from real estate business can be estimated at a reasonable rate of profit by the CIT(A) based on seized material, and appeals related to assessments made under section 153A may not be pressed if not pursued.

The Assessing Officer should exercise discretion under Section 40A(3) by considering business expediency, surrounding circumstances, and the facts of each case, balancing legal requirements with assessee hardship, rather than relying solely on Board circulars.

A statement recorded under section 132(4A) is presumed to be true unless the assessee can rebut the presumption by proving the retraction was made spontaneously.