S. 92C : Transfer pricing-Capital or revenue-Adjustment On account of Advertisement, marketing and promotion (AMP) expenses- Roughly 60% of bills were furnished to AO in original proceedings- Matter remanded to AO for verification.

S. 68 : Cash credits-No return was filed by the lenders-Matter is remanded to prove creditworthiness of lender.

S. 68 : Cash credits–Share application–Non–resident–Having meagre income–Credit worthiness not proved–Addition is held to be justified.

S. 68 : Cash credits-Share capital and premium-issue of share premium is not relevant for cash credits-Identity, genuineness of transaction and creditworthiness of parties established -Deletion of addition is held to be justified.

S. 68 : Cash credits-Share application money–Natural justice violated -Examining such persons in Kolkata at back of assessee would be clear violation of principles of natural justice—Matter remanded. [S. 131]

S. 54F : Capital gains-Investment in a residential house–Property purchased in the name of wife–Loan was sanctioned in the name of wife – Not entitle to exemption. [S. 45]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Sundry creditors were paid in subsequent year- Deletion of addition is held to be justified.

S. 41(1) : Profits chargeable to tax – Remission or cessation of trading liability -Sundry creditors – Produced details of court cases at Kuwait and correspondences with its overseas buyers/agents its efforts for making recovery to justify that these payments were still due from customers albeit same was produced before tribunal for first time—No justification in confirming additions.

S. 40(a)(ia) : Amounts not deductible-Deduction at source -Short deduction of deduction at source–No disallowance can be made. [S.194C, 194J, S. 201]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident -Marketing expenses—Payment made by assessee to foreign entities towards marketing and sale support services were not chargeable to tax in India and assessee was right in law in not deducting any tax thereon – DTAA-India –USA. [S. 195, Art .24(1)]