S. 194A : Deduction at source – Interest other than interest on securities – Non-resident -External commercial borrowings with ICICI Bank Singapore Branch — ICICI Bank Indian resident company and its global income including offshore Branch Chargeable to tax in India – Not liable to deduct tax at source . Matter was set aside for verification .[ S.6(3), 194A (3) (iii), 195 , 201 (1) 201(iA) ]

S. 153A : Assessment – Search- No incriminating material was found in the course of search proceedings – Net agricultural income accepted during assessment proceedings — Addition cannot be made on net agricultural income .

S. 144C : Reference to dispute resolution panel -Transfer pricing- Duty of DRP to decide issues raised by assessee- DRP is directed to pass a reasoned and speaking order dealing with all contentions of assessee after giving reasonable opportunity to assessee.

S. 92C : Transfer pricing – Arm’s length price – Procuring and importing lubricants – TNM is appropriate method – Assessee to be given adjustments for extraordinary costs incurred in first year of operations-AO is directed to re compute the arm’s length price.

S.92C:Transfer Pricing — Arm’s Length Price —Outstanding expenses — Interest — Period of 60 days reasonable within which expenses ought to have been recovered—SBI-PLR rates alone should be calculated without any 3 per cent spread.8.15 Per Cent should be adopted while calculating Arm’s Length Price interest — Opportunity cost to assessee’s funds to be calculated in relation to interest earning capacity in domestic market. [ S.92B ]

S. 80P : Co-operative societies -Primary agricultural credit society – Interest earned on investments made with Sub-treasuries entitled to benefit of deduction [ S80P(2)(a)(i)]

S.37(1): Business expenditure -Capital or revenue -Expenditure incurred on renovation of leasehold building is revenue expenditure .

S.37(1): Business Expenditure — Bogus purchases — Disallowance of 15% of unverifiable purchases is held to be justified .

S.36(1)(iii): Interest on borrowed capital — Disallowance on interest debited to profit and loss account as attributable to amounts invested in capital work-in-progress is justified.

S. 14A : Disallowance of expenditure – Exempt income – Assessing Officer not giving cogent reason for rejecting suo motu disallowance made by Assessee — Assessee need not maintain separate books for expenses incurred in earning exempt income —No disallowances can be made . [ R.8D ]