S. 92CA :Reference to transfer pricing officer -Arm’s length price —Computing Arm’s Length Price without referring matter to Transfer Pricing Officer — Transfer adjustment vitiated – Draft assessment order does not become final assessment order simply by issuing corrigendum — Draft assessment order not valid. [ S.92CA(3) 144C ]

S. 92C : Transfer pricing – Arm’s length price – Comparable Benchmarking of Transaction — Marketing support services same functions – Can be treated as comparable —Deriving its income from manufacturing or trading and indenting services — Not good Comparable for company rendering market support services.

S. 92C : Transfer pricing – Arm’s length price – Debt-free company —Adjustment in relation to notional interest on overdue receivables is held to be not justified- Comparable – Company having controlled transactions — High brand value and high turnover of company —Held not comparables.

S. 80IB: Industrial undertakings – Sub-Licensing income — Royalty — Not related to manufacturing activity – Income excludible on net basis after adjusting loyalty paid against sub-licensing income [ S.80IC ]

S. 74 : Losses – Long-term capital loss — Reduction of share capital — Amounts to transfer —Loss arising due to cancellation of shares allowable as long-term capital loss eligible to be carried forward to subsequent years [ S.2(47) ]

S.68: Cash credit — Unsecured loan — Failure to prove genuineness – Addition is held to be justified .

S.68: Cash credits — Bogus purchases from bogus firm — Forensic Expert’s report showing that account of firm operated in handwriting of assessee and all deposits and withdrawals made in handwriting of assessee —Not availing of opportunity to cross-examine forensic expert —Addition is held to be justified — Addition on account of bogus sales out of bogus purchases will result in double addition — Addition on debit entry to be deleted . [ S.145 ]

S. 68 : Cash credits – Share application money – Source of investment, identity and creditworthiness of investors and genuineness of transaction established – Addition is held to be not valid . [ S.14A, 131, 153A ]

S.68: Cash credits — Share application money — Accommodation entries — Entry provider in his statement not stating investor company one of concerns controlled by him — Assumption Of accommodation entries vitiated by fact -Addition unsustainable.

S. 68 : Cash credits – Share application money — Nature and source satisfactorily explained —Addition is held to be not valid – Derivative loss – Matter remanded to the Assessing Officer .