S. 92C : Transfer pricing-Arm’s Length Price-Payment of application cost-TNMM method–TPO adopted CUP method and determined nil–Separate bench marking is required–Receipt for services-Addition was made without examining the provision of S.37(1)–Matter remanded.

S. 80IC : Special category States-substantial expansion-Entitle to deduction. [S. 80IB (5), 80IC(7)]

S. 44 : Insurance business-Sale of investments-Held to be taxable. [S. 14A]

S. 40A(2) : Expenses or payments not deductible–Excessive or unreasonable–Rent-No written agreement-Both are paying same rate of taxes-Revenue neutral- No disallowance can be made– Rent paid to sister concern–Matter remanded for verification.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident–Re-insurance Premium-Profit of non-resident re-insurance company was taxable in India-liable to deduct tax. [Insurance Act 1938, S.2(9),114A ]

S. 37(1) : Business expenditure-Compensation payable-Unascertainable liability-Not allowable as deduction.[S. 145]

S. 37(1) : Business expenditure-Provision of various expenses- Following the rule of consistency and accounting principle– Addition was deleted. [S. 145]

S. 37(1) : Business expenditure–Apportionment of expenses–STP unit and non -STP unit–Matter remanded.

S. 37(1) : Business expenditure-Demurrage charges-Held to be allowable-Corporate responsibility and expenditure commission- Held to be not allowable as no details were filed.

S. 36(1)(iii) : Interest on borrowed capital-Finance cost-Advertising agency-Held to be not allowable as revenue expenditure as no business income was earned from advertising business or real estate business during the year. [S. 37(1)]