S. 92C : Transfer pricing-Arm’s length price-Guarantee commission was to be charged at rate of 0.50 per cent in respect of corporate guarantee-Interest-Commercial expediency of loan is wholly irrelevant in ascertaining ALP of interest on said loan advanced to AE.

S. 92C : Transfer pricing-Arm’s length price-Comparison-Data should be of same financial year-Delay of 47 days in filing appeal by the revenue was condoned. [S. 253]

S. 92B : Transfer pricing-Corporate guarantee-No material to prove cost in providing corporate guarantee-Addition is held to be not valid-Finance Act, 2012, amendment is prospective. [S. 92C]

S. 92A : Transfer pricing-Associated enterprises-Advance of loan-None of said two entities had individually advanced loan of more than 51 per cent of book value of total assets of assessee-Entities could not be deemed as AEs of assessee. [S. 92A(2)(c), 92C]

S. 80P : Co-operative societies-Source of investment by co-operative society-Revenue is not required to look to nature of investment whether it is from surplus funds or otherwise. [S. 80P(2)]

S. 80IC : Special category States-Deduction could not be restricted proportionately to split/broken period when undertaking undertook substantial expansion and it was eligible on basis of annual profit.

S. 80IB : Industrial undertakings-Addition made towards suppressed production-Entitle to deduction. [Form 10CCB]

S. 80IA : Industrial undertakings-Infrastructure development-Wind Mill-loss prior to initial assessment year which had already been set off, could not be brought forward and adjusted against profits of eligible business. [S. 80IA(5)]

S. 69C : Unexplained expenditure-Business counselling charges-Payment to bogus companies-Reassessment is held to be justified-Disallowance is held to be justified. [S.143(1), 147, 148]

S. 69C : Unexplained expenditure-Purchase of raw material-purported excess money had been received back-Deletion of addition is held to be valid.