S. 132(4) : Search and seizure – Statement on oath – Short term capital gains- Offered in statement recorded during search – Brought forward capital loss of earlier years – Eligible to be set off against short term gains of current year – Set off of loss not to be denied on ground that not claimed in statement recorded during search [ S. 74 ]

S.92C: Transfer pricing -Arm’s length price — Exchange rate fluctuations —Taken part of operating margin [ S.92CA ]

S.92C: Transfer pricing — Arm’s Length Price — Delay in realisation of trade debts — Uniform policy -Associated enterprises and non- enterprises — Addition of notional interest is held to be not justified . [ S.92B ]

S.92C: Transfer pricing — Arm’s length price — Manning service fee —Addition is deleted .

S. 92C : Transfer pricing – Arm’s length price – Huge related party transactions — Unreliable financials — Not Comparables [

S. 92C : Transfer pricing – Arm’s length price -A debt-free company — No interest paid to creditor or supplier nor interest earned from unrelated party- Adjustment of interest is held to be not warranted .

S. 92C : Transfer pricing – Arm’s length price – Information enabled technology services -Comparable-Extraordinary events taking place in relevant period — Excluded from comparable – Interest receivables – No separate adjustment is required – Denial of exemption is not justified [ S. 10A , 92CA ]

S. 80IA :Industrial undertakings – Infrastructure development-
Generation Of Electricity — Initial assessment year — Not required to notionally reduce losses arising from eligible business in earlier years already set off against other business – Losses arising in eligible business subsequent to earmarking of initial Assessment year to be governed by embargo placed in section 80IA(5) of the Act [ S.70 , 71 ,72 ,80IA(4),80IA(5) ]

S. 69C : Unexplained expenditure – Bogus purchases –
Accommodation entries —Trading in gold jewellery – Enhancement by CIT (A) directing to add entire purchases was deleted – Estimate of 10% of bogus purchases Assessing Officer is affirmed . [ S. 132 ]

S. 69 :Unexplained investments – Silver and jewellery belongs to family members – Declared in the wealth tax return to be considered – Addition is held to be not valid [ S.69A , 132 ]