S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Reimbursement of third party cost for marketing and research-Expenses relating to advertisement were on buying of advertisement space in the newspapers-Pass through entities-Other than these three items, all other items should be considered as part of the cost base o and should be marked-up-Order of CIT(A) is affirmed.

S. 90 :Double taxation relief-Salary income earned in USA by a person resident in India-Since all the conditions mentioned in art. 16(2) of the DTAA are not attracted in the case of the assessee, the income of the assessee is taxable in USA and not in India-DTAA-India-USA [Art. 16(1), 16(2)]

S. 90 :Double taxation relief-Service rendered in each projects sites did not exceed threshold limit of 183 days-No profits out of sale equipments as well as installation and commissioning services can be taxed in India-DTAA-India-Singapore [Art. 5(3), 5(4)]

S. 90 :Double taxation relief-Credit for tax paid abroad-Directory-Form No. 67 was filed and uploaded on portal on 18th Oct., 2021 on two months prior to intimation-Matter remanded to the CIT(A) to give credit to the USA income of the assessee and FTC as claimed after due verification.[S. 91, 13991), 143(1), Form No 67. R. 128(9)]

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Adjustment of loss of other units-Separate books of account-Adjustment of loss of other units are not justified. [S.80IA(5),Form No. 10CCB]

S. 80GGC : Contribution-Any person-Political parties-Rashtriya Komi Ekta party-Unrecognised political party-No certificate is furnished in the form of verification of list of documents, etc-Genuineness of the donation is not proved-Not allowable as deduction. [S. 133(6 )]

S. 80G : Donation-Inability of file fresh application owing to technical glitches in the portal-Assessee is entitled to file fresh application under cl. (iii) of first proviso to sub-s. (5) of s. 80G before the CIT(E), in view of Circular No. 7 of 2024, dt. 25th April, 2024 even manually, in case technical glitches continues to disallow filing thereof-CIT(E) is directed to dispose of the application in accordance with law.[S.80G(5), Form No 10AC]

S. 69A : Unexplained money-Income from undisclosed sources-Cash deposits in banks-Demonetization-Sale of goods-Deposited by customers-Addition is deleted. [s. 133(6)]

S. 69A : Unexplained money-Disclosure of unexplained jewellery in the course of search-Income offered in the return of income-Assessing officer is justified in assessing the income as income from undisclosed sources and assessing the income at per section 115BBE of the Act.[S.155BE, 132]

S. 69 : Unexplained investments-Cash deposit-Bank-Demonetization period-Sales-Addition is deleted.