S.115QA: Tax on distributed income to share holders- Buy back of shares – Remittances to non-residents- Appeal pending before Supreme Court -Department agreeing to treat communication as show-cause notice — Direction to assessee to file reply thereto and further directions as to continuance of interim orders. [ S. 2(22) (a) , 2(22(d) , 115O, 245Q ]

S.115JB: Book profit – Interest – Retrospective amendment -Interest is leviable [ S.234B ]

S.115JB : Book profit – Insurance business — Accounts prepared in accordance with Insurance Act, 1938- Provision relating to books of account is not applicable [ Insurance Act , 1938 ]

S.92C:Transfer pricing- Arm’s length price —Appellate Tribunal- Advertising, marketing and publicity expenses —Remand by the Tribunal for determination of arm’s length price is held to be not warranted. [ S.254(1) ]

S. 92C : Transfer pricing – Arm’s length price – Comparable -Question of fact – No substantial question of law. [ S92CA 260A ]

S. 80IB: Industrial undertakings -Manufacture- Making of poultry feed amounts to manufacture — Commercially different and distinct as a commodity – Entitle to deduction [ S .2(29BA ]

S. 80IA :Industrial undertakings – Infrastructure development- Telecommunications Services —Change in shareholding- Losses which have lapsed cannot be taken into account for purposes of computation of deduction .[ S.72(b) , 79 80IA(4) ,80IA(5) (2) ]

S. 80IA :Industrial undertakings – Infrastructure development – Sewage system-Contract with local bodies for development of infrastructure facility -Entitle to deduction [ S.80IA(4) ]

S. 44BB : Mineral oils – Computation – Non-resident – Royalty and fees for technical services – Matter remanded to the file of Commissioner (Appeals)- Interpretation of taxing statutes — Strict interpretation.- when there are two provisions in an enactment which cannot be reconciled with each other, the doctrine of harmonious construction should be applied and attempt should be to interpret the provisions, if possible, giving effect to both- DTAA -India -Australia [ S.44DA , 115A, Art , 12 ]

S.44AB: Presumptive taxation — Construction Business — Appellate Tribunal remanding the matter-The Assessing officer not following the direction of the Appellate Tribunal – Directed the Assessing Officer to follow the direction- Availability of alternative remedy is not bar to entertaining the writ petition [ S.44AD ,144, 251(1),Art , 226 ]