S.92C: Transfer pricing—Selection of comparables—Functionally different—IT enabled services- TNMM – Software developer could not be functionally comparable with a pure captive service provider – Foreign exchange gain or loss is part of operating expenditure/ income.

S.92C:Transfer Pricing—ALP—Separate segment accounts— rejection of segment on ground that ‘weight’ was an appropriate allocation key deserves to be rejected and adjustment so made TPO was to be deleted.

S.80HHC:Export business- Audit report was filed in the name of proprietorship concern – Disallowance of claim is held to be not valid . [ S.158BC ]

S. 69A : Unexplained money – Income from undisclosed sources –Export sales – Export was made by assessee in his proprietorship concern and there was no justification for making an addition as undisclosed export proceeds –Statement of third party – Addition is held to be not justified without giving an opportunity of cross examination. [ S.158BC ]

S. 260A : Appeal – High Court –Without admitting the appeal and framing any question of law and dismissing it is not in conformity with the mandatory procedure –High Court is directed to hear the appeal following the mandatory procedure. [ S.260A(2) ( C ), 260A(3) ]

S. 250 : Appeal – Commissioner (Appeals) – Guidelines for disposal of appeals – Incentive to CIT(A) –Target of disposal – Enhancement and penalty – Impermissible and invalid- Portion of Central Action Plan prepared by CBDT which gives higher weightage for disposal of appeals by quality orders i.e where order passed by Commissioner(Appeals) is in favour of revenue was to be set aside.[ S.119 , 250 (6A]

S. 148 : Reassessment – Notice to dead person- Notice to legal heir of deceased Assessment order is held to be invalid .[S.147 , Art .226]

S. 69C :Unexplained expenditure -Bogus purchases –Trader in fabrics – -Entire purchases cannot be added without disturbing the sales – Addition is to be restricted to the extent of G.P rate .[ S.145 ]

S. 44BB : Mineral oils – Presumptive tax-Gross receipts on account of- Reimbursement of custom duty, service tax paid earlier would not form part of the aggregate amount and not includible in gross receipts . [ S.2(24) , 5, 9 ,43B]

S. 260A : Appeal – High Court -Monetary limit – The matter neither had any cascading tax effect nor did it involve any issues of common principles in a group of matters or a large number of matters-.The withdrawal of the appeal could be permitted in accordance with the CBDT Circular dated July 11, 2018 [ S.119 ]