S. 133A : Power of survey-Stock discrepancy and unexplained cash Offered for taxation in earlier year but Commitment retracted-Once statements accepted by survey team tax should be calculated for relevant year accepted by assessee-Addition made for the year under consideration was deleted.
S. 92C : Transfer pricing-Arm’s length price-Outstanding receivables -Working capital adjustment allowed to assessee-No adjustment called for. [S. 92B]
S. 92C : Transfer pricing-Arm’s length price-Advertising, marketing and promotion expenses-Not international transaction-No adjustment can be made. [S. 92CA]
S. 68 : Cash credits-Excise contractor-Demand drafts taken from certain parties-Not furnishing Permanent Account Number not a reason for making addition. [S. 69A]
S. 68 : Cash credits-Undisclosed bank accounts-Grocery business-Cross deposits and withdrawals-Combined peak credit of both bank accounts to be taken to work out element of undisclosed investments for undisclosed transactions.
S. 56 : Income from other sources-Business income-Director of company purchased one unit in a Hotel, had given for being run by a managing company, said unit could not be construed to be a business of assessee-loss from hotel unit assessed under head income from other sources and not as business loss. [S. 28 (i), 57]
S. 54B : Capital gains-Land used for agricultural purposes-Neither Depositing amount in capital gains account nor using net consideration for purchase of land before prescribed date-Not entitled to exemption. [S. 45]
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Transaction duly considered in Income-Tax returns of payee-No disallowance could be made Advertisement-Franchisee news paper-Liable to deduct tax at source. [S. 194C, 201(1)]
S. 37(1) : Business expenditure-Business promotion expenses-Not practically possible to furnish complete list of gifts to various customers-Quantum of expenditure vis-a-vis turnover would have to be justified-Restriction of 40 Per Cent. of initial total disallowance is held to be reasonable.
S. 37(1) : Business expenditure-Employees stock option plan Expenses-Allowable as revenue expenditure.