S. 92C : Transfer pricing–Arm’s length price–Know-how–Royalty-TPO is not justified in making the addition without applying any specified method.
S. 92C : Transfer pricing–Arm’s length price–Know-how–Royalty-TPO is not justified in making the addition without applying any specified method.
S. 80IB(10) : Housing projects-Residential plus commercial-Commercial user is permitted by local authority was within local limits-Entitle to exemption.
S. 80IA : Industrial undertakings-Manufacture-Activity of compression of natural gas into CNG amounted to manufacture-Entitle to exemption. [S. 2(29BA)]
S. 69C : Unexplained expenditure–Bogus purchases-Alleged use of five credit cards by friends–In response to summons the friends refused use of cards–Addition is held to be justified. [S. 131]
S. 69C : Unexplained expenditure–Bogus purchases-Tribunal is justified in restricting addition on account of alleged bogus purchases to 25 per cent.
S. 69B : Amounts of investments not fully disclosed in books of account–Addition cannot be made merely on the basis of stamp valuation adopted by Stamp authority. [S. 45, 50C]
S. 69A : Unexplained money–Purchase and sale of gold on behalf of other parties-Identity of purchasers was not established– Addition on estimate basis of 3.5% of turnover is held to be justified as against 1% disclosed by the appellant.
S. 68 : Cash credits–Share application money-Income tax returns, balance sheet, confirmations were produced-Deletion of addition is held to be justified. [S. 131]
S. 56 : Income from other sources–Issue of shares at premium-Fair market value of shares-AO has to undertake exercise of determining fair market value of shares-Matter remanded. [S. 56 (2)(viib), 119]
S. 45 : Capital gains–Business income-Sale of shares-Shares settled by settlor – Shares received by way of Employee Stock Option Plan-Assessable as capital gains and not as business income-Entitle to exemption. [S. 10(38), 28(i)]