S. 92C : Transfer pricing–Arm’s length price-Mutually agreed procedure (MAP) adopted by Governments of India and USA in relation to US based transactions for determination of ALP could also be adopted for determining ALP of on –US based transactions.
S. 80IB(10) : Housing projects-Land was in the original owner- Undertaken development of housing project at their own risk and cost-Entitle to deduction.[S. 2(47)]
S. 80IA : Industrial undertakings -Conversion of paddy into rice is a manufacturing activity-Entitle to deduction. [S. 80IB].
S. 80IA : Industrial undertakings–Infrastructure development- Agreement with a nodal agency established by State Government Deduction cannot be denied. [S. 80IA(4)]
S. 80IA : Industrial undertakings-Gross or net-Net of interest excluding expenditure incurred in earning such interest income which should be excluded for purpose of deduction.
S. 69A : Unexplained money–Search–Excess jewellery found which belongs to partners-Addition cannot be made in the assessment of firm. [S. 158BB]
S. 69 : Unexplained investments–Statement on oath-Assets were not found-Merely on the basis of statement in the course of search no addition can be made. [S. 132(4)]
S. 69 : Income form undisclosed-Bogus purchases-The CIT(A) is not justified in enhancing the assessment to disallow 100% of the bogus purchases-The only addition which can be made is to account for profit element embedded in the purchase transactions to factorize for profit earned by assessee against possible purchase of material in the grey market and undue benefit of VAT against such bogus purchases. [S. 251]
S. 62 : Transfer irrevocable for a specified period–Revocable after three years – Income arising by virtue of a revocable transfer of assets would be chargeable to tax as income of transferors and would be included in their total income- Trust cannot be taxed as an AOP at maximum marginal rate. [S.61(1), 62(2), 164]
S. 56 : Income from other Sources-Purchase of shares at Rs. 4 per shares when the market price was Rs. 140 per share-Failure to explain by credible evidence or any reason or no motive for tax evasion- Difference is held to be taxable as income. [S.56(2)(vii) (c)]