S. 92C : Transfer pricing–Arm’s length price–Additional evidence was produced–Matter remanded. [S. 254(1)]

S. 92C : Transfer pricing–Arm’s length price–DRP was right in law in accepting the contention of assessee to grant custom duty adjustment, when the assessee has worked out the adjustment in its own hands while as per Rule 10B(1)(e)(iii), if any adjustment is to be made it should be made in the hands of comparable companies only.

S. 92C : transfer pricing–Arm’s length price–Professional fees-TNMM-CUP method–Matter remanded to the TPO.

S. 92B : Transfer pricing–Corporate guarantee-International transaction-Directed to take 1% as arm’s length price. [S. 92C]

S. 70 : Set off of loss–Long term capital loss against long term capital gains-Long term capital loss arising out of sale of shares cannot be set off against long-term capital gain from sale of shares subjected to STT and claimed exempt u/s. 10 (38)-Directed the AO to allow carry forward of long term capital loss as claimed by the assessee.[S. 2(14) 10(38), 45, 74]

S. 69 : Unexplained investments–Income from undisclosed source-Alleged sale of scraps-Addition is held to be not justified.[S. 4, 145]

S. 68 : Cash credits–Capital gains-Share transactions–Assessee has discharged the onus cast upon him-AO is directed to accept the long term capital gain declared by the assessee. [S. 45]

S. 68 : Cash credits-Bogus sales–Purchase and sales accepted as recorded in the books of account–Books of accounts not rejected-Statement of third party was neither provided nor opportunity of cross examination-Addition by applying the GP rate of 8.8% on sales is directed to be deleted. [S. 44AB, 145]

S. 64 : Clubbing of income–Set-off of business loss of the wife in the assessment of husband-Entire amount of loss resulting from the business started by wife with the gifts received from her husband is liable to be clubbed in the hands of the assessee. [S. 64(1) (iv)]

S. 55 : Capital gains-Cost of acquisition–Justified in claiming capital loss by taking as cost of acquisition of shares–On the next working day–AO has wrongly adopted the weighted average price of next day. [S. 45, 55(2)(ac), 115AD]