S. 92C : Transfer pricing-Arms’ length price-International transactions- Benchmarking of transactions-Comparable-Back office support services-Company providing consultancy business solution and testing and high end business process outsourcing services-Cannot be held to be comparables.
S. 92C : Transfer pricing–Arm’s length exemption-Tax exemption-Arm’s length price on international transactions deserve to be determined. [S. 10A, 10B, 92]
S. 92B : Transfer pricing–Arm’s length price-Corporate guarantee given to associated enterprises–Arm’s length commission on such guarantee restricted to 0. 5%. [S. 92C]
S. 80IC : Special category States-Tea plantation–Manufacturing of tea is not eligible to claim deduction in respect of sale of black tea manufactured from green tea leaf purchased from outside market. [S. 80IC(2)(b)]
S. 80IB(10) : Housing projects-Direction is given to AO to collect information about stage of completion of projects and size of flats — Pro rata deduction to be given if project completed within norms.
S. 71 : Set off loss-One head against income from another-Borrowing funds and making investments in business also paying interest-No evidence assessee diverted funds for non-business purpose-Intra head losses can be set off.
S. 69C : Unexplained expenditure-Purchase of land-Addition of same payments made in hands of landowners-Addition on protective basis not sustainable. [S. 143(3)]
S. 69B : Amounts of investments not fully disclosed in books of account– unexplained investment-Purchase of land-Peak credit–Directed to verify audited cash book entries with payments to landlords and reliable source of cash available for such payments to landowners.
S. 69B : Amounts of investments not fully disclosed in books of account– Unexplained investment-Purchase of land-Addition merely on presumption is held to be not justified.
S. 69A : Unexplained money-Income from undisclosed sources- unexplained cash-Cash flow statement accepted in wealth-tax assessment not to be discarded-Cash balance available as on date of search treated as explained. [S. 132]