S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Functional analysis-Re seller-Performing marketing support service-Foreign exchange gains-Other grounds-Matter remanded to Commissioner (Appeals) for Re adjudication. [S. 251]

S. 92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-Excluded from definition with effect from 1-4-2017-Omission has retrospective effect-Addition is deleted. [S.40A(2)(b)]

S. 80HHC : Export-Manufacturing and letting out vacuum insulated tanks and related products-Lease rent-Business income-Eligible for deduction-Deduction not to be allowed on profits to extent deduction already allowed under Section 8OIA of the Act.

S. 80G : Donation-Mentioning wrong section code-Error typographical and inadvertent-Remanded to Commissioner (E) to treat application under proper section code-Circular No. 7 Of 2024, Dated 25-4-2024 (2024) 463 ITR 14(St). [S.80G(5), Form No 10B].

S. 69C : Unexplained expenditure-Information from Investigation Wing-Purchase transaction is duly explained with supporting evidences-Addition is deleted-Reassessment issue is left open. [S. 147, 148]

S. 69A : Unexplained money-Remand report-Single percentage of Commission for both receipts is not p roper-Matter remanded to Assessing Officer to reconsider issue and apply appropriate rate for estimation of income. [S. 147,148]

S. 69A : Unexplained money-Sales-Demonetisation-Deletion of addition is affirmed.

S. 69A : Unexplained money-Un explained expenditure-Search and Seizure-Fixed deposit receipts in name of wife-Addition is deleted-Amount spent on marriage-Addition on estimate basis-Restricted to 60% per cent of estimated amount-Personal expenditure-No incriminating material is found-Rental payment-Estimation of rent for 18 months-Payment of advance tax-Not able to explain the source-Addition is justified-Overseas Trip expenses and investment in benefit fund-Failure to show the source of investment-Addition is justified-Bank deposits-Seized passbook-Incriminating material-Addition is justified-Payments towards transponder hire, purchase of allied equipment, uplinking facility, and telecom service provider-No evidence of payment-addition is deleted-Bills found in Assessee’s name remanded for re-examination-Imported car-Gift-Denied by alleged gift giver-Matter remanded to determine real owner-Seizure of cash gold and silver article from premises of uncle-Assessment is bad in law [S. 132, 153C, 158BC]

S. 69 : Unexplained investments-Appellate Tribunal-Cross appeal or cross objection-Right of assessee to support order on issue decided against him-Survey-Statement has no evidentiary value-Source of payment-Assessing Officer cannot ignore the registered document-Transaction pertaining to eight years prior to assessment year-Addition is deleted-Marriage expenses of son-expenditure recorded in books of assessee’s wife’s proprietary concern-Deletion is affirmed-Telescoping benefits to additional income and undisclosed outgoings. [S. 69C 131, 133A (3)(iii), 254(1), ITAT R. 27]

S. 68 : Cash credits-Long term capital gains-Information from Investigation Wing-Penny stock-Accommodation entries-Purchase in the year 2010-11-No sale during the year-Transaction cannot be assessed as bogus-Failure to mention section in the notice u/s 143(2)-Assessment order is defective-Credit for tax deduction at source-Issue is not adjudicated by Commissioner (Appeals)-The Assessing Officer is directed to verify the claim. [S. 45, 143(2), 143(3)]