S. 92C : Transfer pricing–Arm’s length price-Only one comparable-Difference in functionality- Matter remanded.

S. 92C : Transfer pricing–Arm’s length price–Export of finished valves and valves in kit form to its AE and also to its group companies across globe -TPO ought to have arrived at ALP of assessee’s sale to its AE by only comparing it with uncontrolled transaction of sale. [S. 92]

S. 80IB : Industrial undertakings-Profit from sale of slag, which was a by-product in manufacture of pig iron, was to be considered as profit from business of industrial undertaking engaged in manufacture and sale of pig iron for purpose of deduction.

S. 72 : Carry forward and set off of business losses–Return was not filed with in prescribed time–Application for condonation of delay was not filed with in permissible time limit – Rejection of application is held to be justified. [S. 119, 139(1), 254(1)]

S. 69C : Unexplained expenditure–Hawala transaction-Bogus purchases–Trading in paper and paper products-Adoption of profit at 12.5 % of alleged bogus purchases is held to be justified. [S. 143(3)]

S. 54B : Capital gains – Land used for agricultural purposes– Denial of exemption on the basis of report of inspector and statement of bataidar is held to be justified. [S. 45]

S. 45 : Capital gains-Transfer- Agreement to sell flats which were yet to be constructed–No transfer has taken place during the year -Not assessable as capital gains. [S.2(47)(v), Transfer of property Act, 1881, S. 53A]

S. 43B : Deductions on actual payment–Provision for Licence fee -Mercantile system of accounting-S.43B(1)(g) inserted with effect from 1-4-2017 will accordingly apply to assessment year 2017-18 and subsequent assessment years. [S. 43B(1)(g), 145]

S. 43(1) : Actual cost–Subsidy-Setting up new industry- Calculation of subsidy on the basis of sales tax or excise duty- Amount of subsidy was not to be deducted from actual cost for purpose of calculating depreciation etc. [S. 4, 32]

S. 42 : Business for prospecting-Mineral oil–Surrender of oil blocks before commencement of commercial production would be treated as surrender for claiming deduction of oil exploration expenditure. [S. 42(1)(a)]