S. 92C : Transfer pricing–Arm’s Length price-CUP method-TNMM- International transactions combined by assessee for showing them at ALP cannot be aggregated where assessee fails to show any inextricable link between these transactions as one not surviving without the other and there is no package deal and the international transaction in question is separately valued and there is nothing to show an understanding that the pricing was dependent upon the assessee accepting all of them together- Matter remanded.

S. 92C : Transfer pricing–Arm’s length price–CUP method- Interest free loan to subsidiary–Shares were allotted– Adjustment is held to be not justified.

S. 92C : Transfer pricing–Inter group services-Payments in accordance with the written agreements-Adjustment is held to be not justified. [S. 92CA]

S. 80P : Co-Operative society—Investments in other co-operative societies – AO is directed to grant exemption if institutions where the assessee has made investments is found to be co-operative society. [S. 80P(2)(d)]

S. 68 : Cash credits—Deposit in bank account-Not maintaining books of account–Presumptive taxation–Return was accepted-Addition as cash credit is held to be not valid. [S. 44AF]

S. 50C : Capital gains-Full value of consideration-Stamp valuation Property not freehold property but occupied by tenants and court cases to get premises vacated pending—Kanpur Development Authority issuing letters to assessee proposing to take over certain portion of his property in connection with road widening— Addition on account of difference in stamp duty and sale deed is not justified. [S. 45]

S. 43B : Deductions on actual payment – Provision for leave encashment- Not allowable unless the amount is actually paid.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Amount not claimed as expenditure-No disallowance can be made-Exemption certificate for non deduction of tax at source- Once certificate has been issued no disallowances can be made- If income is not chargeable to tax in India-No disallowance can be made- Once it is held that income is not chargeable to tax in India, no disallowance can be made. [S. 195, 197]

S. 37(1) : Business expenditure — Provision for non-moving inventory — consistent treatment from year to year in return, allowable for deduction. [S. 145 ]

S. 37(1) : Business expenditure—Provision for warranty expenses — provision made based on transactions carried out in preceding three years on scientific basis and method consistently followed in past such expenditure is allowable. [S. 145]