S. 92C : Transfer pricing – Arm’s length price – comparables- Segmental information is not provided by company in respect of software services, same could not be included as a good comparable-Functionally indifferent companies cannot be selected as good comparable- Fact that a company had a high or low turnover could be no reason to justify its exclusion if it was otherwise functionally comparable.

S. 92B : Transfer pricing–International Transaction–Advertising Marketing and Promotion (AMP) expenses is not an international transaction- Adjustment is held to be not justified. [S. 92C]

S. 80IA : Industrial undertakings–Captive consumption-Power supplied to its divisions -Market value of power supplied to others to be charged

S. 80IA : Industrial undertakings–Loss of an eligible industrial unit is not required to be set-off against profit of other eligible unit

S. 45 : Capital gains- Business income -Short term gains on sale of shares and mutual funds – Rule of consistency is directed to be followed-Assessed as capital gains. [S. 28(i), 111A]

S. 43D : Public financial institutions–Interest income on loans categorised as NPA/sticky loans–Taxable on receipt basis and not on accrual basis. [S. 145]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-No part of services had been either rendered or received in India-Not liable to deduct tax at source on payments made to a non-resident company having no PE in India. [S. 195]

S. 40(a)(i) : Amounts not deductible-Deduction at source-TDS deposited beyond the due date but before the due date of filing the Return of income is an allowable expenditure. [S. 139(1)]

S. 37(1) : Business expenditure-Claim for gifts given to distributors/dealers for promotion where in assessee failed to give list of recipients to be disallowed to the extent of 30%.

S. 37(1) : Business expenditure–Foreign tour expenses–Research manager–Only 20% of expenditure is held to be personal in nature by the CIT(A)is upheld.