S. 92CA : Transfer pricing Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Parent company of subsidiary-Not controlling and determining quantity of production-Sales to associated enterprises under individual contracts-Not payment of royalty-Not profit-shifting mechanism even if royalty embedded in sale price-Contract manufacturer-Royalty payment by subsidiary to its parent company abroad-Comparable to those in open market-Transfer pricing adjustment of royalty is not justified-No substantial question of law. [S.92C, 260A, R.10A, 10E]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Order in conformity with directions of Supreme Court guidelines-No substantial question of law.[S. 260A]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Manufacture or production of GITTI from sand stone blocks-Amounts to manufacture or production.[S.80IB, 260A]

S. 68 : Cash credits-Sundry credits and unsecured Loans-Responding to notice under Section 133(6) and confirming transactions through banks in their statements under Section 131-Order of Tribunal is affirmed-No substantial question of law. [S. 131, 133(6), 260A]

S. 68 : Cash credits-Long-term capital gains-Penny stock-Sunrise Asian Ltd-Exemption-Information from Investigation Wing-Presumptions is not corroborated by evidence-Order of Tribunal deleting the addition is affirmed.[S. 10(38), 45, 115BBE, 133(6), 260A]

S. 37(1) : Business expenditure-Bogus expenses-Construction business-Payments made to Sub-contractors-TDS is deducted-Order of Tribunal confirming the disallowance is affirmed-No substantial question of law. [S.260A]

S. 37(1) : Business expenditure-Provision for contingent liabilities-Order of Tribunal is affirmed-No substantial question of law.[S. 260A]

S. 37(1) : Business expenditure-Bogus expenses-Construction business-Payments made to Sub-contractors-TDS is deducted-Order of Tribunal confirming the disallowance is affirmed-No substantial question of law-SLP of assessee is rejected. [Art. 136]

S. 37(1) : Business expenditure-Provision for contingent liabilities-High Court affirmed the order of Tribunal-SLP of Revenue is dismissed for failure to condone delay of 289 days. [Art. 136]

S. 32 : Depreciation-Revaluation-Actual cost-Taken over assets and liabilities of the firm-Actual cost of assets will be actual cost which assessee paid to predecessor after revaluing assets-Entitled to claim depreciation for subsequent years on basis of actual cost paid-SLP of Revenue is dismissed. [S. 43(1), Proviso, R. 5, Art. 136]