S. 92B : Transfer pricing – International transaction- Interest income on loans and advances- Assessee not disputed that transaction is international transaction however disputed only on notional addition on the ground that only real income be taxed .[ S.92C ]

S. 68 : Cash credits – Sub -contract- Outstanding credits payable to sub contractors where tax was deducted at source could not be added treating same as unexplained cash credit -If addition is up held it will lead to very ubnormal to a govt contractor .

S. 68 : Cash credits – Cash withdrawn from Bank was redeposited after seven months , addition cannot be made as cash credits .

S. 68 : Cash credits – Share capital- Builder and developer- Failed to prove identity and creditworthiness of shareholders- Summons served were retuned back with remark the addressees were not available – Addition was held to be justified .[ S.131 ]

S. 48 : Capital gains –Indexed cost- Since property was acquired by father of assessee in year 1945, indexed cost of acquisition was required to be computed by considering cost of acquisition for year beginning on 1-4-1981 [ S.45, 49(1)(iii) ]

S. 45: Capital gains- Business – Income earned on sale of floor of building was held to be assessable as capital gains and not as business income -The assessee was not a property dealer but a member of the Indian revenue Service, working with the department itself. Only a portion of the property was sold. Profit on sale of land is held to be assessable as capital gains [ S. 2(13 )]

S. 41(1) : Profits chargeable to tax – Remission or cessation of trading liability – Assets and liabilities were transferred to special purpose vehicle -Tribunal failed to give independent finding , accordingly the matter was remanded to Tribunal

S.40(a)(ia):Amounts not deductible – Deduction at source –Caual workers-Labour payment to one or two persons on site for disbursing same among labourers- In absence of any contract to carry out any work with a specified person there is no liability to deduct tax at source . [ S.194C ]

S.40(a)(ia):Amounts not deductible – Deduction at source – A co-operative society formed for the welfare of the employee of the life insurance corporation and all members of assessee is not liable to deduct tax at source- Decision of jurisdictional High Court is binding on the AO [ S. 194A ]

S. 37(1) : Business expenditure – Expenses incurred prior to setting up of business is held to be not allowable as business loss [ S.28(i) ]