S.92C: Transfer pricing- Foreign AE could be a tested party, provided complete financials of said AE along with complete financials of relevant comparables required to benchmark international transaction were made available before TPO, matter remanded .Transaction with AE being higher than ALP, no ALP adjustment could be made matter remanded.

S. 80IE : Undertakings – North – Eastern States – ‘initial assessment year’ would be year in which substantial expansion is completed by assessee which would enable it to generate revenue- Denial of exemption is held to be not justified .

S. 74 : Losses – Capital gains -Unquoted shares-Sale of shares at Rs 2 per share – long-term capital loss on issue of shares cannot be disallowed merely on basis of suspicion and conjectures without making any enquiries in the hands of the purchaser of shares.

S. 73 : Losses in speculation business – Trading of shares was not primary activity-Solitary transaction of sale of shares could not have been treated as speculative business .

S. 72A : Carry forward and set off of accumulated loss and unabsorbed depreciation – Merger – Non-banking finance company (NBFC) – Merger Scheme approved by High Court having in mind larger public interest, Claim of set off of unabsorbed short-term capital loss and unabsorbed business loss incurred by amalgamating companies cannot be denied on ground that amalgamating companies did not own an ‘industrial undertaking’ as defined under S. 72A of the Act.[ S.72, 74 ]

S. 71 : Set off of loss – One head against income from another -Unabsorbed depreciation and brought forward business loss can be set off against income from other sources [ S.72 ]

S. 44BB : Mineral oils – Computation – imparting any services in relation to exploration of mineral oil then royalties/FTS would be taxable under S. 44BB of the Act- Specific provision prevail over other provisions dealing with royalties and FTS . [ S.9(1)(vi), 9(1) (vii), 44DA, 115A ]

S.40(a)(ia):Amounts not deductible – Deduction at source -Professional fees- Failure to deduct tax at source- Disallowance was held to be justified [ S.194J ]

S.37(1): Business expenditure -Capital or revenue- Right to use technical know is held to be revenue expenditure .

S.28(i): Business income- Hire charges –Activity of the assessee being business activity ,hire charges received is assessable as business income and not as income from other sources [ S.56 ]